98 Ohio App. 3d 337 - In Re Brown’s Empirical Analysis
1994
Citation profile
216 state decisions
How this case has been cited
Cited by 216 later decisions — most recently November 2025 · most notably 156 Ohio App. 3d 241 - State v. Baron (2004), 140 Ohio App. 3d 409 - In Re T.C. (2000)
216 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 In re Adoption of Holcomb · In re Burrell · In re Fassinger · 145 Ohio St. 413 - In Re Corey · 20 Ohio App. 3d 203 - In Re Decker
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 216 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“`produce in the mind of the trier of facts a firm belief or conviction as to the facts sought to be established.'”
5 later decisions quote this exact passage“shall determine by clear and convincing evidence whether the offender is a sexual predator. R.C. 2950.09 (B)(3). Clear and convincing evidence is more than a mere preponderance of the evidence; instead, it must produce in the mind of the trier of fact a firm belief or conviction as to the facts sought to be established.”
4 later decisions quote this exact passage“(1) The interaction and interrelationship of the child with the child's parents, siblings, relatives, foster caregivers and out-of-home providers, and any other person who may significantly affect the child; (2) The wishes of the child, as expressed directly by the child or through the child's guardian ad litem, with due regard for the maturity of the child; (3) The custodial history of the child, including whether the child has been in the temporary custody of one or more public children services agencies or private child placing agencies for twelve or more months of a consecutive twenty-two-month period or the child has been in the temporary custody of one or more public children services agencies or private child placing agencies for twelve or more months of a consecutive twenty-two-month period and, as described in division (D)(1) of section 2151.413 [2151.41.3] of the Revised Code, the child was previously in the temporary custody of an equivalent agency in another state; (4) The child's need for a legally secure permanent placement and whether that type of placement can be achieved without a grant of permanent custody to the agency; (5) Whether any of the factors in divisions (E)(7) to (11) of this section apply in relation to the parents and child.”
3 later decisions quote this exact passagee.g. In re L.M. · In re H.W.
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.