Painter v. Graley’s Empirical Analysis
1994
Citation profile
12 federal appellate · 256 state decisions
How this case has been cited
Cited by 369 later decisions — most recently February 2026 · most notably Kulch v. Structural Fibers, Inc. (1997), 73 Ohio St. 3d 65 - Collins v. Rizkana (1995)
12 federal appellate · 256 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 Pickering v. Board of Education of Township High School District 205 Will County Illinois · Connick v. Myers · Elrod v. Burns · Broadrick v. Oklahoma · Thornhill v. Alabama
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 369 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) that [a] clear public policy existed and was manifested in a state or federal constitution, statute or administrative regulation, or in the common law (the clarity element); (2) that dismissing employees under circumstances like those involved in the plaintiffs dismissal would jeopardize the public policy (the jeopardy element); (3) the plaintiffs dismissal was motivated by conduct related to the public policy (the causation element); and (4) the employer lacked overriding legitimate business justification for the dismissal (the overriding justification element).”
45 later decisions quote this exact passage · from the majority“The existence of such a public policy may be discerned by the Ohio judiciary based on sources such as the Constitutions of Ohio and the United States, legislation, administrative rules and regulations, and the common law.”
7 later decisions quote this exact passage · from the majority“a cause of action for wrongful discharge in violation of public policy may exist as an exception to the general rule.”
7 later decisions 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.