25 Ohio St. 3d 331 - In re Schmidt’s Empirical Analysis
1986
Citation profile
148 state decisions
How this case has been cited
Cited by 148 later decisions — most recently November 2025 · most notably In re Whitaker (1988), State ex rel. McCleary v. Roberts (2000)
148 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Santosky v. Kramer
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 148 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“where the grandparents have stood in loco parentis to their grandchild.”
8 later decisions quote this exact passage · from the concurrence“As discussed above, the Smiths had no legal right to custody or visitation with their grandson, and they held no legally protectable interest that was related to Robert, Jr.'s care and custody. Additionally, the emphasis placed on family unity by R.C. Chapter 2151 is limited almost exclusively to the nuclear family; and, unless a child is orphaned or abandoned, or an adult from the child's extended family in some manner has filled the role of parent, R.C. Chapter 2151 does not require that extended family members be made parties to custody proceedings. The record does not indicate that the Smiths ever stood in loco parentis to Robert, Jr. or that they ever exercised significant parental control over, or assumed any parental duties for the benefit of, their grandson.”
3 later decisions quote this exact passage · from the majority“Likewise, the [grandparents] had no legal interest in the care and custody of their grandson, which would have allowed them to intervene [in an adoption proceeding] as of right.... [T]he [grandparents'] `claimed interest' was not legally protectable.”
3 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.