Patton v. Diemer’s Empirical Analysis
1988
Citation profile
2 federal appellate · 517 state decisions
How this case has been cited
Cited by 519 later decisions — most recently March 2026 · most notably Pratts v. Hurley (2004), State v. Wilson (1995)
2 federal appellate · 517 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
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 519 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“is not derived from Civ.R. 60(B), but rather constitutes an inherent power possessed by Ohio courts.”
29 later decisions quote this exact passage“A warrant of attorney to confess judgment contained in any instrument executed on or after January 1, 1974, arising out of a consumer loan or consumer transaction, is invalid and the court shall have no jurisdiction to render a judgment based upon such a warrant.”
4 later decisions quote this exact passage““It was neither incumbent upon appellee to establish a basis for relief under Civ.R. 60(B) nor was it necessary for the common pleas court to derive its authority therefrom. Rather, the ‘judgment’ sought to be vacated constituted a nullity. * * * ” Id. at 70 , 518 N.E.2d at 944 .”
2 later decisions quote this exact passage
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.