48 Ohio App. 3d 55 - Proctor v. Proctor’s Empirical Analysis
1988
Citation profile
137 state decisions
How this case has been cited
Cited by 137 later decisions — most recently December 2025 · most notably State ex rel. Duncan v. Chippewa Township Trustees (1995), 111 Ohio App. 3d 357 - Kilroy v. B.H. Lakeshore Co. (1996)
137 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 Blakemore v. Blakemore · C. E. Morris Co. v. Foley Construction Co. · Schade v. Carnegie Body Co. · Normandy Place Associates v. Beyer · 56 Ohio App. 2d 144 - Eisenberg v. Peyton
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 137 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * merely follows the well-established case authority that an appellate court will not consider any error which counsel for a party complaining of the trial court's judgment could have called but did not call to the trial court's attention at a time when such error could have been corrected or avoided by the trial court. (Citations omitted). Accordingly, * * * we hold that an assignment of error based upon the trial court's adoption of the referee's finding of fact is waived unless an objection to that finding of fact is contained in the party's written objections to the referee's report.”
2 later decisions quote this exact passage““Although the wife objected to the referee’s report, she provided no transcript of the referee’s hearing or other evidentiary material to contest the referee’s findings. Consequently, the trial court could properly adopt the referee’s factual findings without further consideration. Civ.R. 53(E)(6).””
2 later decisions quote this exact passage“in the absence of such a transcript or affidavit, an appellate court will review the trial court's adoption of the magistrate's findings of facts to determine whether the trial court's adoption of that finding constituted an abuse of discretion.”
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.