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← 48 OHIOST2D 176 - Waldmann v. Waldmann

Waldmann v. Waldmann’s Empirical Analysis

1976

Citation profile

88
cited by 88 later decisions
3
states following
October 2025
most recently cited

3 federal appellate · 81 state decisions

How this case has been cited

Cited by 88 later decisions — most recently October 2025 · most notably Peyko v. Frederick (1986), 156 Ohio St. 3d 85 - State v. Tench (2018)

3 federal appellate · 81 state decisions

260197619801990200020102020decided

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 141 Ohio St. 87 - In Re Martin, Jr. · State ex rel. Lambdin v. Brenton · 65 Ohio App. 45 - In Re Heile

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

  1. “In Ohio, the burden of showing that testimony or documents are confidential or privileged rests upon the party seeking to exclude it.”
    4 later decisions quote this exact passage · from the majority
  2. “Even when a case falls beyond the strict letter of R. C. 2317.02(A), the principles of that section apply if the case is plainly within the reason and spirit of it. R. C. 2317.03(H). The confidentiality of a client's address in a domestic relations matter, especially a divorce action, can be a vital feature of the action; it is not uncommon for a spouse who fears for her or his safety to need assurance that their whereabouts will not be disclosed. If a client feels that confidentially divulged matters will not be protected, facts may be withheld which are necessary to competent representation. When the attorney-client privilege exists, the privilege has been held to encompass the protection of the address of the client.”
    1 later decision quote this exact passage · from the majority
  3. “It is the public policy of this state that an attorney shall not testify concerning a communication made to him by his client in that relation.”
    1 later decision 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.