Drain v. Kosydar’s Empirical Analysis
1978
Citation profile
28 state decisions
How this case has been cited
Cited by 30 later decisions — most recently February 2026 · most notably Elston v. Howland Local Schools (2007), 1 Ohio App. 3d 60 - James H. Ex Rel. Ohio Legal Rights Service v. State (1980)
28 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 Ranells v. City of Cleveland
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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'It is undeniable that the state can only act through its employees and officers.'”
2 later decisions quote this exact passage““* * * [T]o permit such ¡punitive] damages against a public corporation is to contravene public policy since the parties who must bear the burden of the punishment are the taxpayers and citizens who constitute the very persons who as a group are to benefit from the public example which the granting of such damages is supposed to make of a wrongdoer.””
1 later decision 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.