65 Ohio App. 3d 768 - Roth v. Roth’s Empirical Analysis
1989
Citation profile
65 state decisions
How this case has been cited
Cited by 66 later decisions — most recently December 2025 · most notably Goldfuss v. Davidson (1997), 83 Ohio App. 3d 757 - Holm v. Smilowitz (1992)
65 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 Strickland v. Washington · Blakemore v. Blakemore · Link v. Wabash Railroad · C. E. Morris Co. v. Foley Construction Co. · 24 Ohio App. 3d 74 - McKay v. McKay
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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Sixth Amendment to the United States Constitution provides a right to effective assistance of counsel in a criminal proceeding. Strickland v. Washington (1984), 466 U.S. 668 , 686 , * * *. The right to be represented by counsel in a civil proceeding where the state seeks to take the defendant's life, liberty, or property is guaranteed by the Fifth Amendment to the United States Constitution as applied to the states by the Fourteenth Amendment. However, in a civil case between individual litigants, there is no constitutional right to representation. The state does provide a forum, via the judicial system, in which litigants can resolve disputes. Litigants may seek to be represented in this forum by attorneys trained in procedure and the law. But it is the litigant himself who selects that attorney. Therefore, the litigant cannot thereafter complain that his attorney was ineffective and require the other litigant to bear the loss for such negligent selection of an attorney. See Link v. Wabash RR. Co. (1962), 370 U.S. 626 , 633-634 , * * *. * * * [A]ny complaint of ineffective assistance of counsel may only be resolved in a malpractice action.”
1 later decision quote this exact passage“Generally, the purpose of a nunc pro tunc entry is to correct an omission in a prior judgment and enter upon the record the judicial action actually taken, but erroneously omitted, from the record.”
1 later decision quote this exact passage“[A]ny complaint of ineffective assistance of counsel may only be resolved in a malpractice action.”
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.