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← 58 OHIOST2D 460 - State v. Sammons

State v. Sammons’s Empirical Analysis

1979

Citation profile

74
cited by 74 later decisions
4
states following
September 2025
most recently cited

74 state decisions

How this case has been cited

Cited by 74 later decisions — most recently September 2025 · most notably 114 Ohio App. 3d 738 - State v. Miley (1996), 104 Ohio App. 3d 812 - State v. Elliott (1995)

74 state decisions

310197919801990200020102020decided

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 Connally v. General Construction Co. · United States v. Harriss · Papachristou v. City of Jacksonville · Smith v. Goguen · United States Civil Service Commission v. National Ass'n of Letter Carriers

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

  1. “(A) No person, who is the parent, guardian, custodian, person having custody or control, or person in loco parentis of a child under eighteen years of age or a mentally or physically handicapped child under twenty-one years of age, shall create a substantial risk to the health or safety of the child, by violating a duty of care, protection, or support . . .”
    7 later decisions quote this exact passage
  2. “In advancing this premise appellant sets forth that “[s]tudies have demonstrated that the working class (i. e., blue collar) parents tend to emphasize conformity to external standards of orderliness, obedience, and respect for adults, and are more likely to rely on the use of physical force as a means of punishment. In contrast middle class (i. e., white collar) parents tend to emphasize self-direction, individualism, and realization of potential, and are more likely to rely on verbal interaction in response to persistent misbehavior.” The foregoing discussion as advanced by appellant in support of the claimed vagueness of this statute is of little weight in applying what may be considered to be a reasonable standard of duty of care and protection of one’s children generally to be applied throughout the community. Whatever the color of the collar, a generally acceptable standard of societal attention to the needs and care of our offspring is not difficult of either determination or application. The norm in our society is for a parent to strive to see that his children are reasonably well nourished, housed, and clothed and reasonably protected from harm, and provided with necessary health care.”
    1 later decision quote this exact passage
  3. ““The constitutional infirmities of vague penal statutes are three-fold. Indefinite statutes fail to provide fair notice that the contemplated conduct is forbidden. United States v. Harriss (1954), 347 U.S. 612, 617 . Such statutes also fail to set reasonably clear guidelines for those charged with their administration, resulting in arbitrary and unequal enforcement. Smith v. Goguen (1974), 415 U.S. 566, 572-73 . Additionally, vague criminal statutes often proscribe conduct that, by modern standards, is normally innocent. Papachristou v. Jacksonville (1972), 405 U.S. 156, 163 .””
    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.