43 Ohio App. 3d 78 - In Re Lay’s Empirical Analysis

Citation profile

20 state decisions

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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “* * * only where there is demonstrated an incapacity on the part of the parent to provide adequate parental care, not [because] better parental care * * * can be provided by foster parents or adoptive parents * * *.”

   4 later decisions quote this exact passage
   e.g. In Re Rashaun B., Unpublished Decision (9-22-2004) · In Re Destiny C., L-08-1147 (10-10-2008)

2. “* * * R.C. 2151.414 (A) requires the trial court to determine: (1) that the board has made a good faith effort to implement the initial and subsequent reunification plans; (2) that the parents have acted so as to leave the child without adequate parental care and that they will continue to do so in the near future; and (3) that it is in the best interests of the child to permanently terminate parental rights.”

   1 later decision quote this exact passage
   e.g. In Re Bender, Unpublished Decision (5-3-2004)

3. “The trial court's finding that permanent custody should be awarded to the Lucas County Children Services pursuant to O.R.C. § 2151.414 (D) (E) was not supported by clear and convincing evidence.”

   1 later decision quote this exact passage
   e.g. In Re Davontae W., L-07-1342 (5-30-2008)