Klein v. Leis’s Empirical Analysis
2003
Citation profile
119 state decisions
How this case has been cited
Cited by 121 later decisions — most recently March 2026 · most notably State v. Lowe (2007), Ohioans for Concealed Carry, Inc. v. City of Clyde (2008)
119 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 City of Chicago v. Morales · Martin v. Ohio · Arnold v. City of Cleveland · State v. Williams · Hilton v. City of Toledo
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 121 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“did not unconstitutionally infringe the right to bear arms.”
4 later decisions quote this exact passage“there is no constitutional right to bear concealed weapons.”
2 later decisions quote this exact passage“enjoins a duty in execution of which that right is to be exercised. If [a person] employs those arms which he ought to wield for the safety and protection of his country, his person and his property, to the annoyance and terror and danger of its citizens, his acts find no vindication in the bill of rights. That guarantee was never intended as a warrant for vicious persons to carry weapons with which to terrorize others. Going armed with unusual and dangerous weapons to the terror of the people is an offense at common law. A man may carry a gun for any lawful purpose, for business or amusement, but he cannot go about with that or any other dangerous weapon to terrify and alarm a peaceful people. Klein v. Leis, 99 Ohio St.3d 537 , 2003-Ohio-4779 , ¶ 8, quoting State v. Hogan, 63 Ohio St. 202 , 218-19 (1900); see also Arnold v. Cleveland, 67 Ohio St.3d 35 (1993), paragraph two of the syllabus. {¶ 13} Here, Smith was charged with violating R.C. 2923.16(B), alleged to have "knowingly transport[ed] or have a loaded firearm in a motor vehicle in such a manner that the firearm is accessible to the operator or any passenger without leaving the vehicle.”
1 later decision quote this exact passagee.g. State v. Smith
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.