T

S

C

of O

WRITING MANUAL
A Guide to Citations, Style, and Judicial Opinion Writing

Effective January 1, 2012

Published for the Supreme Court of Ohio

WRITING MANUAL A Guide to Citations, Style, and Judicial Opinion Writing

MAUREEN O’CONNOR

Chief Justice
PAUL E. PFEIFER EVELYN LUNDBERG STRATTON TERRENCE O’DONNELL JUDITH ANN LANZINGER ROBERT R. CUPP YVETTE M C GEE BROWN

Justices
STEVEN C. HOLLON

Administrative Director

Policy and Research Counsel to the Administrative Director. THE OHIO STATE UNIVERSITY C. THE SUPREME COURT OF OHIO SANDRA H. MARZIALE. DIRECTOR OF LEGAL RESOURCES. Retired July 31.The Supreme Court of Ohio Style Manual Committee JUSTICE JUDITH ANN LANZINGER Chair JUSTICE TERRENCE O’DONNELL JUDGE JUDITH L. . MICHAEL WALSH ADMINISTRATOR. 2011 REPORTER OF DECISIONS. NINTH APPELLATE DISTRICT The Committee wishes to gratefully acknowledge the invaluable contributions of editor Pam Wynsen of the Reporter’s Office. THE SUPREME COURT OF OHIO ARTHUR J. GROSKO REPORTER OF DECISIONS. PRESTON. THE SUPREME COURT OF OHIO MARY BETH BEAZLEY ASSOCIATE PROFESSOR OF LAW AND DIRECTOR OF LEGAL WRITING. FRENCH TENTH APPELLATE DISTRICT STEVEN C. HOLLON ADMINISTRATIVE DIRECTOR. as well as the excellent formatting assistance of John VanNorman. THE SUPREME COURT OF OHIO RALPH W. JR. MORITZ COLLEGE OF LAW.

.5............3 SECTION ONE: CASES .................13 Ohio Administrative Decisions .....18 Abbreviations for Reporters of Ohio Cases .................................................................... Print published .............. 2002 ............................................................................................................. C............26 Abbreviations for out-of-state reporters.... 1............... United States Supreme Court cases ............TABLE OF CONTENTS PREFACE ........................................................... MANUAL OF CITATIONS…………………………………………………........2.......... IX PART I.................................... 1................................................................................. Foreign Cases ........................................24 Non-print published ............ C................... 2002 ........5 Ohio cases decided on or after May 1........ B................................................24 A....3............. Out-of-State Court Cases .............................................................................................................................................. Importance of May 1.5 Ohio cases decided before May 1...........34 The Supreme Court of Ohio i Writing Manual ..... 2002 ......................................................23 1................................19 A..................................................21 Federal circuit court cases .............. B.... B.....................................................................27 Abbreviations for West‘s regional reporters and others ........1 INTRODUCTION TO THE MANUAL OF CITATIONS .4..............................................................................1....... Ohio Court Cases ...........................22 Federal district court cases .......................................................................33 1..19 Federal Cases ..........................26 Public-domain citation formats .........5 1...............6..... 1............5 A..... D............................................. E......................... C........

...........2............................. Ohio Statutes .........................OHIO CITATIONS AT A GLANCE .................................... 4...........................................40 SECTION THREE: STATUTES AND ORDINANCES ...2............................................................. 5............................................42 Ohio Municipal Ordinances ................5.............................4.......................................48 Federal Rules .....41 Legislative acts................................................. 3.39 United States Constitution ........... Treatises........43 Out-of-State Statutes .......................1.. chapters............................................................................................ and Dictionaries ............................................................35 SECTION TWO: CONSTITUTIONS ........................................................................... Ohio Rules ........................ C............................... 3....................................................41 Section numbers........................44 Miscellaneous Foreign Statutes................................5............................ Abbreviations ...................... 2............1....50 SECTION FIVE: SECONDARY SOURCES .................41 A..............3.....45 SECTION FOUR: RULES AND REGULATIONS .......51 The Supreme Court of Ohio ii Writing Manual ....................................................................................49 Federal Regulations .............................................................................. 3......47 4.......................1.......................................................................................................................................2..............38 2..............................................1.............................................................................................47 Ohio Local Rules of Court ............49 Ohio Regulations .....................................51 5............................ ....3....................41 3.........................51 Texts... 4. 3.. 4........................................................43 Federal Statutes . and titles ........................... 4...........4......................... Ohio Constitution ........ B.............................2.............. Restatements .....

................................................................................................................. Annotations ................... B..................................................................................................63 A................................ Citations Omitted ...........7.......................................59 Short-form citations for cases with a WebCite ................61 Signal Words ....................................................................... Generally ............................56 Internet ................4........................................................................................................................................63 Style ..70 The Supreme Court of Ohio iii Writing Manual .................................69 Attribution of a quotation within a quotation ............................................59 A..............................59 6........53 A.......53 5.......... D.............. E.6.... 5................ B.......................... Law Reviews ......................................................................... B.....55 Ohio Attorney General Opinions ..........................60 Short-form citations for sources other than cases ........ 5...........................................55 Encyclopedias ....... Definition .....................8................................ Use ........63 Common signals............................59 Information within a short-form citation ............................... Elements of citation .......................................... 5.............................. 5.57 SECTION SIX: MISCELLANEOUS CITATION RULES ... B...............................................................1.............63 Use of signal words .............................59 Short-form citations for cases that have no WebCite ..................56 Nonlegal Magazines and Newspapers .5................2........................................... Short-form Citations .......... C.53 Title and source ....................................................... D.............................69 A..................................3............64 6......................................................5.......................3........................................................................ C................................................ 6.

................................................. Months of the Year ...4...... .....73 Emphasis sic.......................................73 A........................9...................... STYLE GUIDE INTRODUCTION TO THE STYLE GUIDE .................................... ........................................................ General ................72 Emphasis Sic........................... 6.................................................. supra.....10.............87 The Supreme Court of Ohio iv Writing Manual . and infra ................................................................................7..74 Emphasis deleted ..... 6..76 Use of Id.............70 History affecting precedential value .. Emphasis Added.........................76 Abbreviations in the Style or Citation of a Case...............74 6........... Explanatory Case History ....... D............................75 Names of months ............................................................................................................75 Unabbreviated words .75 A............................. Emphasis Deleted ........71 6...........................................................................83 A............................... B...........................84 PART II........................................................ Abbreviated words ................................................................................................ B.......................................................................73 Emphasis added .................................................6..........................................................................5..................................................70 A......................76 6.......... 6... Placement of Citation.........................83 Supra and infra ......................................................................................... C............... B........ D... C..... Style ......... Id....... Spacing within Parentheses in Citations ..................75 Ordinal numbers.......6...8...... B..........................

.. .................1....... Lists .....103 SECTION TWELVE: 12..............................89 Public Offices.........................105 Identification ......................................2.......... 7......................... 11.....99 Block Quotations...........6.103 Reverse Italics ........... ..................3.....................................................................................................4........................105 Use and Overuse ...................................89 Titles of Persons .............................................................................. 12...............................5........105 13.. 10.....................105 The Supreme Court of Ohio v Writing Manual .............101 ITALICS ........................................... 13........................................ 10................. and Entities .............................................................................99 SECTION ELEVEN: FOOTNOTES .............................................................................................................................89 7...............1..................................... 7..............................................................................2...........98 Ellipses ..........101 11..........SECTION SEVEN: CAPITALIZATION.........1.................................97 Placement of Quotation Marks Relative to Other Punctuation .............................................................................................................................................................................2...........2.3.............................. Use of Italics ................91 USE OF NUMBERS ........................... 10..............................................................103 SECTION THIRTEEN: ACRONYMS....................97 10..................................... ABBREVIATIONS............................... 10................ Agencies...........................................................1...............2....1....................................... Use of Footnotes ............................................................................................ Definition .............................97 Punctuation of Quotations...... 10............... Proper Nouns ........................90 DATES IN TEXT .....................................93 SECTION EIGHT: SECTION NINE: SECTION TEN: PUNCTUATION ...................................99 Placement of Footnote Numerals Relative to Punctuation.. 13....................................101 Citations in Footnotes ................... AND PARENTHETICAL REFERENCES .............3.........

.......... 15................................................................................2.............113 15............................................................................................108 In the Matter of ..113 Form of Headings ..........107 The ―Cite-As Line‖ ... STRUCTURE OF A JUDICIAL OPINION INTRODUCTION TO STRUCTURE OF A JUDICIAL OPINION ...... Appellees..............................................109 Original actions .................5.....................................................................................................2......................... Overview ......................................106 SECTION FOURTEEN: THE CASE CAPTION ............................. 14............................................................................127 SECTION EIGHTEEN: OUTLINE OF A JUDICIAL OPINION ...................................131 19...............107 14..................................... Plurals ......................... Use of Headings .... D..............110 Consolidated cases .........13.......105 Parenthetical References ................1...... 14....131 The Supreme Court of Ohio vi Writing Manual ............................4...........125 SECTION SEVENTEEN: AUTHORIAL DISCRETION ................................................ B................................................................................................ 13................................................. E......................................................109 Miscellaneous Caption Matters..113 SECTION SIXTEEN: COMMONLY MISUSED WORDS AND PHRASES ..........................................................3.........................1......................................109 A............... 14........................................................... The Formal Case Caption .............................................110 References to juveniles ...................1......... C.4..........................................115 PART III...............................................................................129 SECTION NINETEEN: EXAMPLES OF OPINIONS CONSTRUCTED ACCORDING TO THE OUTLINE ............................111 SECTION FIFTEEN: HEADINGS ............................................109 Cross-appeals ..............................................

.................... B...............................................................................................................1............................................................................ 20.......154 INDEX ....................................................................................... Headnotes .................................3......................153 Concurring in part and dissenting in part .................4....131 A..153 Concurring in judgment only ................2...................................... Components of an Opinion .......149 General Dispositions ..................2..........153 Categories ...............149 Splintered Judgments ..........................149 20............ Generally ............................................154 Other categories ............................................ D.. B............................155 The Supreme Court of Ohio vii Writing Manual ........ Overview .....................19.1.............................................................................. C................................ E.........................................................150 Judgments Ordering Parties to Act .....................................................131 Syllabus .....................................................................................153 A.......................................................................................2...131 SECTION TWENTY: DISPOSITIONS ............................................. 21............................. 20...........................................................................153 21............. Concurring .................... 20...........................................................................................154 Dissenting ..........151 SECTION TWENTY-ONE: SEPARATE OPINIONS .........

The Supreme Court of Ohio viii Writing Manual .

Moyer. Subjects covered include capitalization. the committee hopes that it will be useful in writing opinions and drafting briefs and pleadings. the Structure of a Judicial Opinion. the Ohio Supreme Court Writing Manual is the first comprehensive guide to judicial opinion writing published by the court for its use. The Supreme Court of Ohio ix Writing Manual . It offers an outline setting forth the basic components of an opinion in the traditional sequence.PREFACE _____________________________________________________ Composed under the direction of the Ohio Supreme Court Style Manual Committee at the request of the late Chief Justice Thomas J. Part III. the writing manual addresses broad areas of interest to all judges and lawyers. Although Ohio judges and lawyers are not required to follow this manual. they are strongly encouraged to use it in writing opinions and briefs. the Manual of Citations. statutes. and other sources. is a guide intended to assist writers of judicial opinions. followed by several examples written in the Supreme Court style. captions. punctuation. Part I. provides examples for each category. and commonly misused words. the Style Guide. It sets forth rules for the forms of citation for cases. The Supreme Court will follow this manual in its opinions. and explains the use of WebCites. use of footnotes and headings. Consisting of three parts. Although judges and lawyers are not required to conform to the Writing Guide. Part II. provides direction on certain aspects of style used in Supreme Court opinions. governs the citation format used in Supreme Court opinions and other print-published opinions.

The Supreme Court of Ohio x Writing Manual .

MANUAL OF CITATIONS The Supreme Court of Ohio 1 Writing Manual .PART I.

The Supreme Court of Ohio 2 Writing Manual .

387.800.2d.9580. Ohio 43215-3431. first appeared in January 1985.3d). the Writing Manual states its directives in rule format.‖ ―Rules and Regulations. The 2002 version brought the manual into compliance with the revised Rules for Reporting Opinions adopted by the Supreme Court effective May 1.C. This 2011 Ohio Supreme Court Writing Manual supersedes the 1985 manual. the interim edition. Ohio case citations no longer include Ohio Bar Reports (OBR) or Ohio Opinions (O.g.S.‖ e. O. followed in July 2002 by the Revisions to the Manual of Citations.S. 1982 instead of Section 1982. Telephone: 614. 65 South Front Street. The Manual of Citations contains several changes to citation style.. 6th Cir.. by category of source (―Cases.‖ and ―Miscellaneous Citation Rules‖).ohio. Title 42.‖ ―Secondary Sources.Code.‖ ―Statutes and Ordinances. Persons preparing documents for filing in the Supreme Court should follow the Manual of Citations. U..A.‖ e. Part II of the manual.6.gov. is divided into six sections.O.S.‖ ―Constitutions.INTRODUCTION TO THE MANUAL OF CITATIONS _____________________________________________________ The Manual of the Forms of Citation Used in the Ohio Official Reports. Its purpose was to make uniform the forms of citation used in opinions published in the Ohio Official Reports. the Manual of Citations. provides guidance in matters of style. an interim edition was released. The federal circuits are now identified using ―Cir.C. instead of C.. and the 2002 revisions. is offered as an aid to drafters of opinions. 2002. Conformance to another generally recognized citation manual is acceptable. The most notable are: • • • • • • The date of a judicial opinion now appears at the end of the citation. Citations of print-published appellate cases now identify the district of decision. E-mail: REP@sc. Columbus. The Supreme Court of Ohio 3 Writing Manual .g.826. In July 1992. the Style Guide.O.9010.O. Part III. a forerunner of the Writing Manual. Each section contains divisions pertaining to that category of source. If you have any comments on the Writing Manual. Unlike previous versions. toll-free at 1. Federal statutes are now cited using ―U. 42 U. Signals are now italicized. please contact the Reporter‘s Office at the Supreme Court of Ohio. Structure of a Judicial Opinion. Part I. O..

The Supreme Court of Ohio 4 Writing Manual .

within parentheses.3d. The Supreme Court of Ohio 5 Writing Manual . and O.. Ohio Court Cases. Supreme Court of Ohio cases In citations of Supreme Court of Ohio cases decided before May 1. NOTE: When the writer wishes to pinpoint a particular page of a case. Do not use the WebCite number in citing these cases.1. B. O. the official citation followed by the North Eastern Reporter. Those sources are cited only when they are the only available source for a case. NOTE: A number of Ohio Supreme Court cases decided before May 1. 2002 1.O. A.2d is the unofficial reporter. Since that time. and Ohio Misc.3d 10.2d.O.g. in italics. 2002 Beginning on May 1.O.g. place the elements of the citation in the following order: • • • The name of the case. the Supreme Court‘s website became the repository of all opinions of the Supreme Court... 80 Ohio St. and the Court of Claims.) 1. separated by a comma. 2002. 684 N.gov/ROD/docs/.2d. Servs.sc. the word ―Ohio. 2003 -Ohio1234.ohio. The year of decision. In Ohio. Importance of May 1. 2002.3d. each opinion posted to the Supreme Court‘s website has been assigned its own unique number or ―WebCite. the current official reporters are Ohio St. e. Immediate Med.‖ and a number unique to that opinion. have been assigned WebCite numbers but have not been assigned paragraph numbers. Inc. i. as well as selected opinions of the state‘s trial courts. only the page of the official reporter is provided.. followed by a comma.‖ The WebCite is composed of three elements: the year of decision. Ohio cases decided before May 1. the courts of appeals.” see page 35. See.SECTION ONE: CASES ______________________________________________________ (For ―OHIO CITATIONS AT A GLANCE. The search index can be accessed at http://www. The full parallel citation. NOTE: Ohio Bar Reports (OBR) and Ohio Opinions (O. 2002.E.3d) are no longer included in the citation. Davis v.. Ohio App.. e.2d 292 (1997). while N.e.E.

NOTE: Use this example when specifically citing one paragraph of a multiparagraph syllabus. Bebout v. 154 N. Burger Brewing Co.3d 23. NOTE: The reference to the footnote (“fn. The Supreme Court of Ohio 6 Writing Manual ..E. not 378-79.E. Bar Assn. 546 N. Util.. Cleveland Metroparks Bd. NOTE: Use the above example when referring to a minority opinion.”) follows the year.2d 873 (1984). Note that the pinpoint page is provided only for the official reporter. 459 N. Scioto Valley Ry. of Revision. 9 Ohio St. 358.E. 459 N. 766 N. 47 Ohio St. Greene Cty. 378-379.3d 309. 26. Walters v. concurring in judgment only). Knox Cty. 89 Ohio St.E. Thomas.2d 886 (1984). 2002. NOTE: Case decided on April 24. NOTE: Use this example when referring to a specific page. 42 Ohio St.E. v. 9 Ohio St. Marrek v. Wright 230 (1833). 329 N.E.3d 551. 3. v. v. & Power Co. J. Tappan 227 (1818). paragraph two of the syllabus. v. O’Brien v. the full number is provided for the ending page of the range. Egelhoff. Simmonds. Agricultural Soc.2d 693 (1975).E. syllabus.2d 151 (2002).3d 116.2d 932 (1989) (Douglas. Note also that when citing a range of pages. Bd. so use this citation form. Comm.3d 194.HOW TO CITE SUPREME COURT OF OHIO CASES DECIDED BEFORE MAY 1.2d 377. 733 N. fn. Liming. Somerby v. use 378-379. Pub. 95 Ohio St. NOTE: Use this example when citing a syllabus composed of one paragraph. That is. 320 (1926). 554. Kennedy. 115 Ohio St.. Tappan. of Commrs. 2002 Lorain Cty.2d 1141 (2000).

2.. Ohio courts of appeals cases a. the case number is preceded by the district number. For print published cases. In non-print published cases. separated by a comma.2d.O. 2001-Ohio-2597. e... 766 N. No. followed by North Eastern Reporter. Print published cases In citations of Ohio courts of appeals opinions that were decided1 before May 1. followed by a comma. have been assigned WebCites and paragraph numbers and should be treated as if they were decided after that date.O. e. i. 5th Dist.g. Those sources are cited only when they are the only available source for a case. No. The full parallel citation. NOTE: The district of decision is now required in all citations of court of appeals cases. the official citation when available. 1 A few print published appellate cases decided before May 1.E.3d 414. ___.. 146 Ohio App.1(B)(2)(b).e. 2002. within parentheses.O. The following map and list show all 12 Ohio appellate districts and their constituent counties. O.). below. See Section 1. The appellate district and year of decision. not Fairfield App. The Supreme Court of Ohio 7 Writing Manual . place the elements of the citation in the following order: • • • The name of the case. Hilyard. NOTE: Ohio Bar Reports (OBR) and Ohio Opinions (O.g. 2002. and O.3d) are no longer included in the citation. __. in italics. Dunkel v. the district appears just before the year in the parenthetical at the end. See.2d 603 (4th Dist. as shown in the examples below.

OHIO APPELLATE DISTRICTS MAP The Supreme Court of Ohio 8 Writing Manual .

Hardin. Muskingum. Morrow. Crawford. and Washington Ashland. Medina. and Noble Cuyahoga Lorain. Shelby. Preble. Fulton. Columbiana. Gallia. Marion. Mahoning. Holmes. Mercer. Perry. Madison. Paulding. Ross. Auglaize. Lake. Ottawa. Fayette. Fairfield. Huron. Clermont. Summit. Hancock. Lucas. Athens. Licking. Delaware. Guernsey. Richland. and Trumbull Brown. and Wyandot Adams. Morgan. Highland. Hocking. Vinton. Seneca. Carroll. Jefferson. Williams. Stark. Logan. and Wood Belmont. Clinton. Union. Sandusky. Harrison. Portage. and Wayne Franklin Ashtabula. Pickaway. Pike. Jackson. Clark. Geauga. Miami. and Warren Fourth Fifth Sixth Seventh Eighth Ninth Tenth Eleventh Twelfth The Supreme Court of Ohio 9 Writing Manual . Butler. and Tuscarawas Erie. Coshocton. Monroe. Darke. Lawrence. Van Wert. and Montgomery Allen. Scioto. Putnam.OHIO APPELLATE DISTRICTS LIST First Second Third Hamilton Champaign. Defiance. Knox. Greene. Henry. Meigs.

2d. 351. and O. 1983). in italics. 16 Ohio App. 52 Ohio App.O. b.O..1959).2d 296 (1st Dist. 501 (1st Dist.2d 798 (1st Dist. The date of decision (month.. Non-print published cases For non-print published Ohio court of appeals cases decided before May 1. Cahill.1978). written as No.2d 747 (8th Dist. day. and year).2d 68 (5th Dist. 165 N.O. 30 Ohio Law Abs.E. Kessler v. v.1922).1939). 460 N. Allison Div.3d 291. ___. 370 N.HOW TO CITE OHIO COURTS OF APPEALS CASES DECIDED BEFORE MAY 1. 292. of Review. 32 N..3d) are no longer included in the citation. Paul Mercury Indemn.1977). 321. St.E.E. O. 2002 / PRINT PUBLISHED State v. Motors Corp. The Supreme Court of Ohio 10 Writing Manual . Crandall.O.. Cincinnati Traction Co. followed by a comma. Bd. NOTE: Ohio Bar Reports (OBR) and Ohio Opinions (O. The number of the district in which the case was decided. Co. Gen. An electronic-database citation. Cincinnati v. Hepner v. 2002.3d 144 (1st Dist. if available. The case number. Gray v.2d 348. Those sources are cited only when they are the only available source for a case. Brown. preceded by a comma. 11 O. place the elements of the citation in the following order: • • • • • The name of the case. 496. NOTE: The pinpoint is provided only for the official reporter. 9 Ohio App.E.

3. No. 2001 Ohio App. LEXIS 4870 (Oct. beginning with the official citation when available. have been assigned WebCites and paragraph numbers and should be treated as if they were decided after that date. 30. See. 2 A few print published trial court cases decided before May 1. 1979). The court and the year of decision. Std. 766 N. 8th Dist. 2001 WL 1346130 (Oct. 1979 WL 210632. 39908.g. NOTE: Any electronic-database citation is acceptable. of Cl. 1979). Siebe v. Fairview Park. 2002 / NON-PRINT PUBLISHED State v. 2001). 1979 Ohio App. 2002. use the West star page or the Lexis page as a pinpoint. Oil Co.2d 46. *4 (Dec. Croston. 4th Dist. 4th Dist. preceded by a comma. NOTE: When a Westlaw or Lexis cite is available. of Cincinnati. 30. e. Print published cases In citations of Ohio trial court opinions that were decided2 before May 1.). 01CA22. No. 01CA22. 117 Ohio Misc.2d 1070 (Ct. or Std. 8th Dist. v. Univ. LEXIS 11428. Fairview Park. An electronic-database citation. Oil Co. Ohio trial court cases a. 39908. No. place the elements of the citation in the following order: • • • • The name of the case. 20. or State v. followed by a comma. *4 (Dec. separated by a comma. followed by North Eastern Reporter. 20. in italics. 2001-Ohio-4109. v. 2001).. No.HOW TO CITE OHIO COURTS OF APPEALS CASES DECIDED BEFORE MAY 1. within parentheses. when available. The Supreme Court of Ohio 11 Writing Manual . Croston.E. The full parallel citation. 2002.

State v.C. such as Ohio Nisi Prius Reports. 1 Ohio N. an abbreviation for the court of decision must precede the year of decision within the parentheses.2d 824 (C. 1894 Ohio Misc. O. M. Welter. Ct.1947). The case number. when available. 50 Ohio Law Abs. Welter v.1971).P. = probate court. within parentheses (month. followed by a comma. Those sources are cited only when they are the only available source for a case. 267 N.P. Bauer. 5.O. NOTE: The pinpoint is provided only for the official reporter. 46. 103.O. 1894 WL 637 (1894).P. 199.P. An electronic-database citation.C. 1 Ohio Dec.O. The court of decision. 105.P. 75 N. and year). that are not print published. J. place the elements of the citation in the following order: • • • • • The name of the case. and O.E. day. Courts of decision are abbreviated as follows: C. written as No. b. LEXIS 44 (1894). NOTE: Ohio Bar Reports (OBR) and Ohio Opinions (O. 27 Ohio Misc. Saam. = Court of Claims of Ohio. = court of common pleas. 199. The Supreme Court of Ohio 12 Writing Manual . in italics. 105. or State v. 2002 / PRINT PUBLISHED State v. = court of common pleas.2d 442 (C.E. NOTE: C. preceded by a comma. 1 Ohio N.2d.C. P. ___. = municipal court. The date of decision. = juvenile court. HOW TO CITE OHIO TRIAL COURT CASES DECIDED BEFORE MAY 1. 2002.3d) are no longer included in the citation.In citations of trial court opinions. Bauer. unless the reporter itself identifies the court.. of Cl.P. 103. 44. 1 Ohio Dec. Non-print published cases For Ohio trial court cases decided before May 1.

Paragraph numbers. are used to pinpoint text. i. No. followed by the opinion‘s Supreme Court WebCite.P. 1992). The full parallel citation.. 2002 1.. Inc. not page numbers. & Radiator Shop. Porter v. 70890CVF-124. 1990 WL 693198 (Nov.3d 121 and after. Auto Elec. v. Cent. 1990). C. 26. 2002 / NON-PRINT PUBLISHED Fairfield Cty. New Philadelphia M. not in parentheses. NOTE: No Westlaw or Lexis citation is available for this case. followed by a comma.C. Allstate Ins. Franklin C.HOW TO CITE OHIO TRIAL COURT CASES DECIDED BEFORE MAY 1. followed by the North Eastern Reporter. The Supreme Court of Ohio 13 Writing Manual . The date of decision appears in the WebCite. in italics. Ohio cases decided on or after May 1. 95 Ohio St. beginning with the official citation. Co. place the elements of the citation in the following order: • • The name of the case. NOTE: No Lexis citation is available for this case.. 2002. Supreme Court of Ohio cases In citations of print published Supreme Court of Ohio cases decided after May 1. all separated by commas. 91CVH02-1112 (July 24. No.e.

2002-Ohio2220. PTZ Trading Ltd. Zaino. paragraph two of the syllabus. ¶ 72 (Cook. separated by commas. Godwin. NOTE: When citing a footnote. Ellwood Engineered Castings Co. fn. 768 N.E.HOW TO CITE SUPREME COURT OF OHIO CASES DECIDED ON OR AFTER MAY 1. v. ¶ 15.. in italics. ¶ 13. dissenting). v. fn. 1.2d 707. NOTE: Use this form when citing one paragraph of an opinion. 2.3d 314.E. 98 Ohio St. followed by the North Eastern Reporter. 95 Ohio St. 2006-Ohio-3563.. The Supreme Court of Ohio 14 Writing Manual .3d 367. 786 N. The full parallel citation. 95 Ohio St.2d 458. 2002Ohio-2427. 850 N.” Mid-America Tire. Ohio courts of appeals cases a.3d 424. thus. that are print published and have a WebCite. Inc. 2002. place the elements of the citation in the following order: • • • The name of the case. Print published cases with WebCite available In citations of Ohio appellate cases decided on or after May 1. 110 Ohio St. 767 N. Bowling Green v.E.. followed by a comma. The appellate district within parentheses.2d 698.E. each paragraph is lettered. NOTE: Use this form when citing one paragraph of a multiparagraph syllabus. Co. 2003Ohio-1812. Wheeling & Lake Erie Ry.2d 619. J. When a footnote contains more than one paragraph. include the paragraph number in which the footnote appears. ¶ a. 2.3d 58. 2002 Bonacorsi v. beginning with the official citation when available. “See ¶ 22.

not by county. The case number. E.E.3d 472.). 3d Dist. 4th Dist.. that are non-print published and have a WebCite. 2002. 2005-Ohio-1797. 154 Ohio App.. place the elements of the citation in the following order: • • • • The name of the case. followed by a comma. _____ and followed by a comma. 796 N. No.. 827 N. 2003-Ohio-4669. Non-print published cases with WebCite available In citations of Ohio appellate cases decided on or after May 1. Wright. etc. HOW TO CITE OHIO COURTS OF APPEALS CASES DECIDED ON OR AFTER MAY 1. 2002 / NON-PRINT PUBLISHED AND WEBCITE AVAILABLE State v. NOTE: The writer no longer has the option of using “Franklin App. as in the example. The court of decision is identified by district. in italics. 1st Dist. ¶ 40 (8th Dist. 160 Ohio App.2d 989. 10th Dist.). The opinion‘s WebCite.3d 231. 2003-Ohio-5994. 2d Dist. State v.. 2002 / PRINT PUBLISHED AND WEBCITE AVAILABLE Byer v. Jones.2d 835 (11th Dist. written as No.g. Jones. The Supreme Court of Ohio 15 Writing Manual . 02AP-1390. The number of the appellate district in which the case was decided.E.HOW TO CITE OHIO COURTS OF APPEALS CASES DECIDED ON OR AFTER MAY 1. b..” The appellate district must be identified.

McFaul. use the same citation form used for cases decided before May 1. Print published cases In citations of Ohio trial court cases print published on or after May 1. Ohio courts of appeals cases‖ of ―B. not page numbers. Non-print published cases‖ under ―2.) in parentheses. 81165. Ohio trial court cases a. 2002 WL 988560 (May 1. followed by the opinion‘s Supreme Court WebCite.c. all separated by a comma. 3. 2002). in italics. 2002. The full parallel citation. not in parentheses. 1st Dist. P. • Paragraph numbers. or Muntaser v.. 117 Ohio Misc. that are not print published and for which a WebCite is not available. 2002 (i. followed by a comma.C. 2002). 2002 / NON-PRINT PUBLISHED AND WEBCITE NOT AVAILABLE State v. 2002 Ohio App. The court of decision (C. M. or State v. 8th Dist. Sampson. 2002. are used to pinpoint text.e. Non-print published cases with no WebCite available When citing appellate cases decided on or after May 1. 2002 Ohio App. 8th Dist. C-10547. place the elements of the citation in the following order: • • The name of the case. HOW TO CITE OHIO COURTS OF APPEALS CASES DECIDED ON OR AFTER MAY 1. 81165. Sampson.P.C. 1st Dist. No. C-10547. LEXIS 2928 (June 16. 2002).‖ above).2d 8 and after). LEXIS 2020 (May 1. No. No. 2002). beginning with the official citation. McFaul. 2002 WL 1308355 (June 16. 2002. No.. The date of decision appears in the WebCite. Muntaser v.. Ohio Cases Decided Before May 1. that are not print published (see ―b. The Supreme Court of Ohio 16 Writing Manual . followed by the North Eastern Reporter.

Mun. 2009-Ohio-4271. No.). WebCite available In citations of Ohio trial court cases decided on or after May 1. Ct. Inc. Co. of Rehab.2d 919 (P. The Supreme Court of Ohio 17 Writing Manual . separated by commas: • • • The name of the case. Ohio State Univ. 844 N. in italics. v. & Corr. 2006-Ohio1104.C. 2002 / NON-PRINT PUBLISHED AND WEBCITE AVAILABLE Atkinson v.C. Auth.). of Cl.E. The opinion‘s WebCite.2d 48. Ct. Dept. O’Brien v.2d 1. 136 Ohio Misc. 2003-Ohio-7363.2d 179 (M.. Intercargo Ins..E. 2002 / PRINT PUBLISHED Cuyahoga Metro. 2005-Ohio-7139. 2002.HOW TO CITE OHIO TRIAL COURT CASES DECIDED ON OR AFTER MAY 1. 861 N.). Harris. v. No. 2008-10315-AD. 2006Ohio-6918. 127 Ohio Misc. Non-print published cases i. of Cl. 139 Ohio Misc. ___.. of Cl.2d 606 (C. Pipe Contrs. Hous. No. b.P.E. In re Wurgler. 2004-10230. HOW TO CITE OHIO TRIAL COURT CASES DECIDED ON OR AFTER MAY 1. that are not print published and that have a WebCite (a category limited to Court of Claims cases).. followed by a comma. place the elements of the citation in the following order. Ct. 805 N.2d 96.

Ulrey Foods. place the elements of the citation in the following order: • • • • • The name of the case. An electronic-database citation. No. 27. No. that are not print published and for which a WebCite is not available.C. The date of decision (month.ii. Ohio Cases Decided Before May 1. 2002‖ above). Sigler v.2. in italics. Non-print published cases‖ under ―3. if available. year). 2002 that are not print published (see ―b. State. ___. Ohio trial court cases‖ of ―B. NOTE: No Westlaw or Lexis citation is available for either case. Ohio Administrative Decisions. Richland C. use the same citation form used for cases decided before May 1. followed by a comma. preceded by a comma. 2002 / NON-PRINT PUBLISHED AND WEBCITE NOT AVAILABLE Kimmel v. 2002. 11. The Supreme Court of Ohio 18 Writing Manual . Inc. WebCite unavailable In citations of Ohio trial court cases decided on or after May 1. 2008). day. The agency of decision. In citations of Ohio administrative decisions. 2005-CVH-006795 (Apr. 2005). HOW TO CITE OHIO TRIAL COURT CASES DECIDED ON OR AFTER MAY 1. 1. written as No.P. Franklin M. The case number.. 07 CV 1863 (Aug.

............3. 2005-T-1609....2d Ohio State Reports..... Power Co.... Comm........ Second Series (1964-1982) . NOTE: No Westlaw or Lexis citation is available for this case.. Ohio State Reports. BTA No.. Stores.. or In re Columbus S.. Ohio App. Ohio App.... 2006 WL 1763724... Third Series (1982-date) . 99-025..HOW TO CITE OHIO ADMINISTRATIVE DECISIONS Board of Tax Appeals: Rich’s Dept.. 7..... Ohio St.. Ohio Appellate Reports. Util... Second Series (1963-1982)... Ohio St.. 2009 Ohio Tax LEXIS 2046 (Feb.... Inc... 05-376-ELUNC.... 1999).. Wilkins..3d The Supreme Court of Ohio 19 Writing Manual .... Inc......... State Employment Relations Board: In re Norwood. 2006 Ohio PUC LEXIS 356.............. 05-376-ELUNC.3d Ohio Appellate Reports (1913-1964) . Stores....... Pub..2d Ohio Appellate Reports.. Wilkins........ at *5 (June 28.. Ohio St..... BTA No... 3.... Ohio App........ SERB No........... 2009).. Third Series (1982-date) . at 3-168 (Oct..... No... v...... Comm.. 2009).. 2009 WL 294413 (Feb.. 3... Pub... Util.. or Rich’s Dept............. Public Utilities Commission of Ohio: In re Columbus S.. v... Power Co. 1.. Abbreviations for Reporters of Ohio Cases... 2006).... 2006)... at *2 (June 28. No. Use the following standard abbreviations when citing various reporters of Ohio cases: ABBREVIATIONS FOR REPORTERS OF OHIO CASES Reports (1821-1851) . Ohio Ohio State Reports (1852-1964) ... 2005-T-1609..

..........) Ohio Circuit Decisions (1885-1901) ............... Ohio Courts of Appeals Reports (1917-1922).............. Ohio Law Abs...... Ohio Dec........ Ohio N..............................................P..............O...O.. Ohio N..C.................C... Wright‘s Ohio Supreme Court Reports (1831-1834) ............... O......... Ohio Misc...S.......... Tappan‘s Reports (1816-1819) .......P............ Ohio Opinions.................. Tappan Weekly Law Bulletin (1876-1921) ... Ohio Law Abstracts (1923-1964) .......... Second Series (1954-1973) ........................2d Ohio Opinions. Wright The Supreme Court of Ohio 20 Writing Manual .... OBR Ohio Supplement (1937-1946) .......... Ohio C....................ABBREVIATIONS FOR REPORTERS OF OHIO CASES – CONT.....B.. Ohio C.2d Ohio Circuit Court Reports (1885-1901) ................... Ohio Circuit Court Reports...... Ohio Supp...... Ohio Nisi Prius Reports... Ohio C..) Ohio Decisions (1894-1920) .. Ohio C..... Ohio Miscellaneous Reports...... Ohio Decisions Reprint (1840-1893) ...............................................O........................................ Ohio Miscellaneous Reports (1963-1982)......(N....S. Ohio Dec..........A......... Second Series (1982-date) Ohio Misc.......... Third Series (1973-1982) ........Rep.. Ohio Nisi Prius Reports (1894-1901) .... New Series (1903-1934)........... W............ O..................... O....D.......... New Series (1903-1917) .....L.......3d Ohio Bar Reports (1982-1987) ...(N......... Ohio Opinions (1934-1956)....

47 L. 173 L. 107.1.2d 629 (1976) (Marshall.Ed. 47 L.S.S.S. Reports volume and page number. 129 S.Ed.Ct. 356 (1867). Turner. in italics. 187 U. 27 L.Ed. United States v.S. 41 L. NOTE: When using a pinpoint. 130. United States Supreme Court cases In citing the opinions of the United States Supreme Court.S.Ct. 1841. Ventris.2d 138 (1985). (2009) NOTE: When a pinpoint citation is required but is not available in U. followed by the Supreme Court Reports. use the pinpoint cite from the Supreme Court Reports.W. ___. Missouri. Cummings v. Federal Cases. 70 U. 1846.. Peck.W. McFarland v.Ed. Bank of New York.Ed. The full parallel citation. 162 (1810). 3 L.2d 213 (1970). provide blanks: ___U.S. Dutton v. 1138. Byrnes. 184. 400 U. beginning with the official citation. provide page number for official volume only. 74.Ct. 23 S.S. 246. 84 L.S. 191.Ed. Evans. ___ U. Kansas v.2d 801. 87. 71 U. The Supreme Court of Ohio 21 Writing Manual . 10 U.L. Roberts v. followed by a comma.___. A. in parentheses.2d 1039 (1974). 128. dissenting). 3090 (2009).Ed. 18 L. followed by the Lawyers' Edition. 105 S. 91 S. 96 S.Ct.S. 1357. When citing a case that has not yet been assigned as U. 425 U.L. 699-700.2d citation is available.S. HOW TO CITE UNITED STATES SUPREME COURT CASES Beer v. 162 (1902). Use United States Law Week (U. 210. Nixon.Ed. S.S.S. Heckler v.S. place the elements of the citation in the following order: • • • The name of the case. 277.) only when no U.S. separated by commas. The year of decision.4. 143.Ct. 470 U. Reports.. or L. 3090. 683. 94 S.Ed.Ct. J.. 248. 418 U. United States..Ct. Fletcher v.

F. No.1949). in italics. place the elements of the citation in the following order: • • • • • The name of the case.2d. F.. Genesco. 5th Cir. The Supreme Court of Ohio 22 Writing Manual . App. HOW TO CITE FEDERAL CIRCUIT COURTS – UNREPORTED CASES Moreno v.Cir. Thorpe v. written as No.g.C. An electronic-database citation. Curry. 06-11277. The case number. or F. Federal circuit court cases In citations of officially reported federal circuit cases.. No. 2007 WL 4467580 (Dec. Thorpe.B. or Moreno v. 2007). written as 1st Cir...2006). The circuit number. if available.Cir.2003). 2007 U. The official citation (generally. Inc. HOW TO CITE FEDERAL CIRCUIT COURT CASES – REPORTED CASES Bass v. 364 F. place the elements of the citation in the following order: • • • The name of the case..2d 205 (5th Cir.. day. 2d Cir. Hoagland. 2d Cir. within parentheses (e. preceded by a comma. The date of decision (month. 20. 20. 2007).1966). Curry.2d 692 (D. followed by a comma. 440 F. written as 1st Cir. etc. Schoenhaus v.. 172 F. 5th Cir.S. The circuit number.. 06-11277.3d 1354 (Fed. year). followed by a comma. with no intervening space. etc. 10th Cir.3d). In citations of federal circuit cases that are not officially reported. in italics.. LEXIS 29505 (Dec. followed by the year of decision. ___.

Pa.D. 292 F. or F..Ohio 1997).D. aff’d sub nom.Ohio 1972).).R. in italics.Appx. The year of decision is preceded by the abbreviation ―Bankr.Supp. Opinions of bankruptcy courts may be found in Bankruptcy Reports (B. The court of decision (district and state.D. aff’d.. 428 F. NOTE: No space follows “Ga.C. and the state (Bankr. 57 F. United States v.Ohio 1968). The official citation (generally. Baylor v.). Heath v. 264 (N.1972). place the elements of the citation in the following order: • • • The name of the case.D.R. Blake. F. United States v.R. 66 (S.D.1977).D..D. Opinions of the district courts are found primarily in the Federal Supplement (F. followed by the year of decision. 841 (E.1970).1971). Mading-Dugan Drug Co.D. 429 F. 573 F. of Edn. within parentheses. but cases before about 1932 can be found in the Federal Reporter (F.Supp..).Supp.Supp. 52 F. Federal district court cases In citations of officially reported federal district court cases. 350 F.2d). the Federal Rules Decisions (F.S.D.Supp. HOW TO CITE FEDERAL DISTRICT COURT CASES REPORTED CASES Forbes v. NOTE: A space follows “Ohio” because it is not an abbreviation.2d 1303 (3d Cir. Duriron Co.. but not division). and the Federal Appendix (Fed.Ga.Ill. Gulf Oil Corp.2d 387 (6th Cir.‖ the district. 243 F.2d). followed by a comma.Supp.Ohio 1917). 107 (S.). Wilson. 830.D. Atlantic Richfield Co. 509. Crews v.1978). The Supreme Court of Ohio 23 Writing Manual . and F. Stephenson v. 511 (N.Supp.R. 360 (S.. 106.” because it is an abbreviation. Westerville Bd.

LEXIS 11642 (Nov. in italics. Abbreviations for out-of-state reporters‖ below) appears followed by the word ―App. within parentheses. preceded by a comma. Out-of-State Court Cases. but not division). Dist. An electronic-database citation. if one is available. if the case is from the state‘s highest court. o If the case has no official reporter:  The name of the state (abbreviated or in full. 13. day. 13. N.D. 1987).. The unofficial citation.  The name of the state (abbreviated or in full. 1987 WL 33806 (Nov. Print published In citations of out-of-state court cases that are print published. Hughes.Ohio No. Hughes. 1987 U.D. Abbreviations for out-of-state reporters‖ below) appears before the year. written as No. N.S. as set forth in ―D. place the elements of the citation in the following order: • • • • The name of the case. The official citation. 1. place the elements of the citation in the following order: • • • • • The name of the case. The date of decision (month. as follows: o If the case is officially reported.In citations of federal district court cases that are not officially reported. The year of decision. CR 86-98. The court of decision (district and state. The Supreme Court of Ohio 24 Writing Manual . CR 86-98.Ohio No. A. or United States v. followed by a comma. followed by a comma. as set forth in ―D. HOW TO CITE FEDERAL DISTRICT COURT CASES UNREPORTED CASES United States v.5.‖ if the case is from an appellate court. if available. The case number. year). 1987). ___. only the year will appear in the parentheses. in italics.

Johnson v.2d 256. 482 S. 310 A.W. 289 A.2d 538 (1939). Fenco Handbag Mfg. 337 P. Wolf v. 379.Rptr. 495 P. 69 Misc. State v.W. Mut.. The Supreme Court of Ohio 25 Writing Manual . Co.HOW TO CITE OUT-OF-STATE COURT CASES – PRINT PUBLISHED Fendelman v.3d 943. = Missouri Court of Appeals. 116.2d 503 (1974). Taylor. NOTE: Tex.Commw.App.2d 509 (1972). Martin v. 261 Ore. 404 A.Crim.2d 315 (Fla. 173.1991). 9 Utah 2d 17.D.2d 59 (1959). aff’d. NOTE: Mo. 21 Cal.W. 270 Md. 545. Bank of Am. 148 Cal. 3 A.I. Turley v. 459 Pa.2d 864. People.2d 970 (1978). 329 A. N.Joseph v.2d 299 (1972). Wellenkamp v.Y.S. Seabrook v. Lawley v. In re Estate of Cavill. 189 Ark. 5 Pa. Life Ins. 110 Vt. 39 A. Bay Ridge Properties. Rosselot.2d 273 (1972).2d 291 (1972). Goodwill.1977).App.1979).App. = Florida Supreme Court. Giguere v. Gissen v. Richards v. Kansas City. 582 P..2d 225. Co.2d 701.2d 707 (Tex. State. 353 So.App. = Florida Court of Appeals.App. NOTE: Fla. of New York. 464 (R.1967). NOTE: Fla.W. 702 (Fla.2d 461 (Mo.1972).2d 457.. 80 So. 411. State v. 329 N. 830 (Mo. 232 (La. Anderson. NOTE: Names of states are not abbreviated in case captions.1974).1955). 291. 71 S.App.Y. Luck. 216..2d 694 (1934). Supervisor of Assessments v. 516 S.2d 773 (1973). Lowery. 815 S. 199 So. = Missouri Supreme Court. Lesieure. = Texas Court of Criminal Appeals.S. 333 N.Crim. NOTE: Mo.2d 829. Huntingdon Twp.

2d 282. HOW TO CITE OUT-OF-STATE COURT CASES . App.App. 1-06-3026. in italics. No. The case number. Lynch. HOW TO CITE PUBLIC-DOMAIN FORMATS State v. 27. VA. 1995). 2010 ND 229.B.W. Public-domain citation formats A number of states have developed their own public-domain citation forms. The court of decision. LEXIS 446 (May 16. The date of decision (month. Staples v.App. 0282-94-2. C. Va. Marinez. 2010 WI App 34. Michaud. Adams. or D’Agostino v. if available. 1995 WL 293043 (May 16. 1995 Va.NON-PRINT PUBLISHED CASES D’Agostino v. year). No. day. or El-Amin v. Adams. ___. Lynch. followed by a comma. The Supreme Court of Ohio 26 Writing Manual . 2008 WL 527059 (Feb. LEXIS 140 (Feb. App. 324 Wis. 2008 Ill. place the elements of the citation as follows: • • • • • The case name. 2008). Ill. Moore.App. No. similar to Ohio‘s WebCite. 2008). 0282-94-2. 791 N. written as No. El-Amin v. 27.2d 511. 2003 ME 133. Use these citation forms when they are available. 1-06-3026.2d 1288. 1995). No. 781 N. State v. Non-print published For out-of-state court cases that are not print published. An electronic-database citation. preceded by a comma.W.App. ¶ 7.2d 376. 836 A. Ill.

......Rptr...2d California Reports.. California Reporter............................................ Second Series...................................Cal.................................2d California Appellate Reports.............................Cal.................. Second Series .........................................Cal............Ariz....Cal.................Cal.3d California Appellate Reports.............................4th California Appellate Reports.. Second Series (West) .............Cal.................... Fourth Series ...........Ariz..Rptr...........Ark....................................................Alaska Arizona Reports ............ Arkansas Appellate Reports ........ California Reports.......................App............Cal........................App..............4th Colorado Reports ..... Third Series ...D.......... Alaska Reports ....... California Appellate Reports...... Arizona Appellate Reports ..............Ala... Abbreviations for out-of-state reporters Use the following abbreviations when citing official reporters for other states or territories: ABBREVIATIONS FOR OUT-OF-STATE REPORTERS Alabama Reports ................2d... Third Series ..............Rptr......................................................Ark.............. Alabama Appellate Reports ........Cal............Colo.........3d California Reports..App.. California Reporter (West) .......... California Reports .....App................3d....................................App....Cal.....................................................App................................................ California Reporter..........Ala...... Fourth Series ............................App.. The Supreme Court of Ohio 27 Writing Manual ................ Arkansas Reports .. Third Series (West) ........................Cal.............................Cal........................

............. Florida Supplement......................Ill...........................Del................. Florida Reports ...........Fla............. Delaware Chancery Reports .......2d Illinois Appellate Reports ..............Conn.........2d Georgia Reports ..............................Supp..Fla....App.Ill...... Second Series .............App............................Ch.........Ill...............................................................................................2d Illinois Appellate Reports........................Haw..Supp........................................................................ Colorado Appellate Reports ...............................Cl............ Illinois Appellate Reports..........Ill.............3d Illinois Court of Claims Reports ...............................................................................................................Ill........ Connecticut Supplement .............. The Supreme Court of Ohio 28 Writing Manual .........................Conn.... Illinois Reports........Supp... Hawai‗i Reports ...................Ill....... Delaware Reports .............................. Third Series ................ Indiana Reports .......App....................... Connecticut Appellate Reports ...........Ga..............................Ct........App.......................App............Ind.....................ABBREVIATIONS FOR OUT-OF-STATE REPORTERS – CONT..Del..........Fla.... Georgia Appeals Reports ..App............... Florida Supplement .........................................Haw..................Conn..........................................................App................... Connecticut Reports .................................Ga.................. Second Series ............Idaho Illinois Reports .............................. Hawai‗i Appellate Reports ........ Second Series.............Colo................. Idaho Reports ..................................................

............................Mo.........Mo..................ABBREVIATIONS FOR OUT-OF-STATE REPORTERS (CONT.. Maine Reports ....Kan...App.....................................................Mich...... Second Series ..................... Kansas Court of Appeals Reports................App..... Mississippi Reports ................................Ct...................... Kansas Court of Appeals Reports ......... Kentucky Appellate Reports . Michigan Reports ..................................... Massachusetts Appeals Court Reports……………………..Ky..........App................................................. Maryland Reports ...........App.... Louisiana Courts of Appeal Reports ..............................App.................................. Missouri Appeals Reports .................) Indiana Appellate Reports .Kan. Iowa Reports ..............................................Ky..........2d Kentucky Reports .................. Massachusetts Reports .... Maryland Court of Special Appeals Reports ...................................................App...... Missouri Reports ...App......Iowa Kansas Reports ......................Mich........................................Md......................... Minnesota Reports ......Mass.......... The Supreme Court of Ohio 29 Writing Manual .............................................La..................... Michigan Court of Claims Reports ...Kan......................Mass..........Me......Mich..........................La......................................Minn................................................................................. Louisiana Reports................Ct..............................................................App........Cl..............Miss..........Md..............Ind.............................. Michigan Appeals Reports ..............................App............................................

..........................N............. Second Series ...........App.................................... Second Series ...N.....C. The Supreme Court of Ohio 30 Writing Manual .......N...J...............2d Appellate Division Reports....... New York Reports.................App...H........ Second Series .............M.......N...........................Navajo Rptr....L....... New York Reports……………………………...................................Y...................... New Mexico Reports.. New Jersey Superior Court Reports ............ Supreme Court ...N....... Nevada Reports .... Miscellaneous Reports..Y..............................................................Y............N...............A.......S..... New York .....A................D............N.......Eq...Super................................................N........ New York Supplement.................... New Hampshire Reports .....Mont....N..... New Jersey Law Reports ................................. Nebraska Reports ........................ Appellate Division Reports.........................J.........................ABBREVIATIONS FOR OUT-OF-STATE REPORTERS (CONT... North Carolina Court of Appeals Reports ...............J......................... New Jersey Reports ..N.J................ New Jersey Equity Reports ......) Montana Reports .Y.....Misc.....................Neb.....................N.......... Nebraska Appellate Reports .............2d North Carolina Reports .............................................2d New York Supplement ...........................N......S............................Neb.. Navajo Reporter ................D.....................Misc................Nev.............................C..................................... Second Series .........2d Miscellaneous Reports......

....... Rhode Island Reports ..................................) North Dakota .....R.......................................................... The Supreme Court of Ohio 31 Writing Manual .......D....R..&C.............................. Pennsylvania District & County Reports.................&C...........Pa.. Fourth Series ..............Crim... Official Translations of the Opinions of the Supreme Court of Puerto Rico……………………………P.........................Pa.................Pa...................................................D..... Oklahoma Criminal Reports .... Third Series ..............Offic................Pa...............S.........C.Super......4th Pennsylvania District Reports ......D..Or...Or...................N...........................D......Commw.. South Dakota Reports ..Pa..... Puerto Rico Reports .3d Pennsylvania District & County Reports........ Oklahoma Reports ........ABBREVIATIONS FOR OUT-OF-STATE REPORTERS (CONT.........&C..................D...S...............I............................................................D..Trans.............. South Carolina Reports ..R......P.........Okla....Pa.. Pennsylvania District & County Reports ...App.......................... Second Series....&C......Okla........................... Oregon Reports ..............D........2d Pennsylvania District & County Reports............................ Pennsylvania State Reports .........................................Pa.................... Pennsylvania Commonwealth Court Reports ................Pa............ Pennsylvania Superior Court Reports .... Oregon Court of Appeals Reports ....

...................... Wisconsin Reports..App............App.............Wis.......... Second Series .........Wash........................Vt............... Second Series .................................................................................... Tennessee Criminal Appeals Reports .................................Wis........Tenn................... Texas Civil Appeals Reports.....Terr............................................. Wisconsin Reports ..2d Washington Appellate Reports ..................Tex. Second Series .................ABBREVIATIONS FOR OUT-OF-STATE REPORTERS (CONT.. Virginia Reports ...........................................Utah 2d Vermont Reports .................... Virginia Court of Appeals Reports .............App.....................2d Wyoming Reports ......................... Utah Reports ........................Utah Utah Reports......Crim...Civ...Crim........) Tennessee Reports ............................................ West Virginia Reports .......App....................... Tennessee Court of Appeals Reports ................Tex................................................ Texas Criminal Reports.......................................Va.Wash....Va.............. The Supreme Court of Ohio 32 Writing Manual .................... Washington Territory Reports................................Tenn.Wash........Tex.......App........Wyo..................................................................Tenn....................App.......................Va.......... Texas Reports ...............W........................................................ Washington Reports .......................Wash.......................... Washington Reports...............................................................

.... Second Series.... Second Series..........E............P........................W.. The Supreme Court of Ohio 33 Writing Manual ................................................2d South Western Reporter ........................................N. North Western Reporter................N....................... Second Series ....................................L..B.......E.................... South Western Reporter....................N......................................So............2d Southern Reporter ...S...S............................................ Second Series .......... South Eastern...........W......W...3d South Eastern Reporter ..P..................... Second Series ......E.......................R......N....... Southern Reporter...................................S.................. Abbreviations for West’s regional reporters and others Use the following list when citing West‘s regional reporters and other reports: ABBREVIATIONS FOR WEST’S REGIONAL REPORTERS AND OTHER REPORTS National Labor Relations Board............T.........C...N............................................................................... Third Series ..........................So..........P............S............... North Eastern Reporter .. North Eastern Reporter............2d Pacific Reporter.......E................ Pacific Reporter.....2d Tax Court of the United States Reports . Second Series .........2d North Western Reporter ......2d Pacific Reporter .....E.....W............

followed by a comma. 12 (Austl. 299 N. Green v. 1978 N.2d 818 (1981). NOTE: Bankr. The King v.L. = Bankruptcy Court In re Amendment of Part 31.R.D.R. Mar-Jac Poultry Co.. 85 F.R.B. 207 C.Rep.R.Use the following examples in citing West‘s regional reporter and other reports: HOW TO CITE WEST REGIONAL REPORTERS AND OTHER REPORTS In re H & W Ent.. Smith.1981). First Report & Order. Foreign Cases. 1 (1990). Inc.L.L. The Supreme Court of Ohio 34 Writing Manual . HOW TO CITE FOREIGN CASES Jones v.C. In re Miller. Generally.1996). 48 (1977). place the elements of a citation for foreign cases in the following order: • • • The case name in italics.6. 73 (1962).C. 136 N..Iowa 1982). Perkins. 441 (1783). Elion Concrete.L. Orange. 1. 10 B. The year of decision in parentheses.B.Md.Z.R. 19 B. 582 (N. 778 (Bankr.R. 106 Eng. The volume and page number of the official reporter.

OHIO CITATIONS AT A GLANCE _____________________________________________________
Examples of the most commonly used case citation forms are provided for easy reference. A full explanation of the rules follows. NOTE: For cases decided before May 1, 2002, place the date at the end of the citation.

HOW TO CITE CASES DECIDED BEFORE MAY 1, 2002 Supreme Court: State v. Carter, 93 Ohio St.3d 581, 585, 757 N.E.2d 362 (2001). State ex rel. King v. Portsmouth, 27 Ohio St.3d 1, 3, 497 N.E.2d 1126 (1986). State v. Parker, 44 Ohio St.2d 172, 339 N.E.2d 648 (1975), syllabus.
NOTE: When citing a syllabus, place it after the date.

Reformed Presbyterian Church v. Nelson, 35 Ohio St. 638, 644 (1880) (Johnson, J., dissenting).
NOTE: When citing a minority opinion, place the parenthetical identifying it as such after the date.

Courts of Appeals: State v. Johnson, 134 Ohio App.3d 586, 591, 731 N.E.2d 1149 (1st Dist.1999).
NOTE: The appellate district is identified at the end, with the date.

Hays v. Nemenz, 7th Dist. No. 88-C-40, 1989 WL 53618 (May 22, 1989). or Hays v. Nemenz, 7th Dist. No. 88-C-40, 1989 Ohio App. LEXIS 1853 (May 22, 1989). Cincinnati v. Black, 8 Ohio App.2d 143, 220 N.E.2d 821 (1st Dist.1966). Gen. Industries, Inc. v. Jones, 89 Ohio App. 43, 100 N.E.2d 703 (9th Dist.1950). Strauss Bros. Co. v. Long, 27 Ohio App. 17, 160 N.E. 635 (1st Dist.1927).
The Supreme Court of Ohio 35 Writing Manual

HOW TO CITE CASES DECIDED BEFORE MAY 1, 2002 (CONT.) Trial Courts: Daniel v. Univ. of Cincinnati, 116 Ohio Misc.2d 1, 761 N.E.2d 1168 (Ct. of Cl.2001). Moscow v. Moscow Village Council, 29 Ohio Misc.2d 15, 504 N.E.2d 1227 (C.P.1984). NOTE: For cases decided on or after May 1, 2002, there is no need to add a date at the end of the citation unless there is no WebCite.

HOW TO CITE CASES DECIDED ON OR AFTER MAY 1, 2002 Supreme Court: State v. Campbell, 100 Ohio St.3d 361, 2003-Ohio-6804, 800 N.E.2d 356, ¶ 14-15. Robinson v. Bates, 112 Ohio St.3d 17, 2006-Ohio-6362, 857 N.E.2d 1195, paragraph two of the syllabus. Cincinnati Bar Assn. v. Statzer, 101 Ohio St.3d 14, 2003-Ohio-6649, 800 N.E.2d 1117, ¶ 23-33 (Moyer, C.J., dissenting). Courts of Appeals: Swartzenruber v. Orville Grace Brethren Church, 163 Ohio App.3d 96, 2005-Ohio-4264, 836 N.E.2d 619, ¶ 5 (9th Dist.).
NOTE: The appellate district is identified at the end, in parentheses.

In re Abram, 10th Dist. Nos. 04AP-220, 04AP-221, and 04AP-222, 2004-Ohio-5435, 2004 WL 2283938, ¶ 9-10. or In re Abram, 10th Dist. Nos. 04AP-220, 04AP-221, and 004AP-222, 2004-Ohio-5435, 2004 Ohio App. LEXIS 4484, ¶ 9-10. Trial Courts: State v. Roblero, 133 Ohio Misc.2d 7, 2005-Ohio-4805, 835 N.E.2d 792 (M.C.).

The Supreme Court of Ohio

36

Writing Manual

HOW TO CITE CASES DECIDED ON OR AFTER MAY 1, 2002 – CONT.

Kantos v. Lopez, Franklin C.P. No. CV-00-024671 (Aug. 6, 2002).
NOTE: Unpublished disposition, no WebCite, Westlaw, or Lexis citation available.

The Supreme Court of Ohio

37

Writing Manual

The Supreme Court of Ohio 38 Writing Manual .

Article IV. separated by commas: • • • Name of Constitution. place the elements in the following order. Article XVIII. Section. HOW TO CITE THE OHIO CONSTITUTION Ohio Constitution. NOTE: The sequence of the elements of a citation of a constitution is the reverse of the former style. Section 2(B)(1)(g). Constitution.1. NOTE: Amendments to and named clauses of the Constitution are written out in words and are capitalized. Ohio Constitution.SECTION TWO: CONSTITUTIONS ______________________________________________________ 2. the Ohio Constitution the Constitution the Constitution of the state of Ohio the Home Rule Amendment the Due Process Clauses of the Ohio and United States Constitutions the Equal Protection Clause the Modern Courts Amendment The Supreme Court of Ohio 39 Writing Manual . When citing the Ohio Constitution. Article. Section 3.

2. Section. Clause (―cl.S. place the elements in the following order. Article.‖).S. Article II. HOW TO CITE THE UNITED STATES CONSTITUTION U. Constitution the Due Process Clause the Equal Protection Clause The Supreme Court of Ohio 40 Writing Manual . Section 1 the Fourteenth Amendment the Sixth Amendment to the U.2. Section 3. cl. Constitution.S. separated by commas: • • • • Name of Constitution. Constitution. When citing the federal Constitution.” Fifteenth Amendment.” not “of. NOTE: “United States” may be abbreviated. NOTE: The preposition is “to. Section 1. Eighteenth Amendment to the U. NOTE: Amendments to and named clauses of the Constitution are written out in words and are capitalized. 1. United States Constitution.

.. NOTE: “R...C. B.....19 and 4511........... Ohio Statutes..................C........C............ 4511....R....... The Supreme Court of Ohio 41 Writing Manual . Revised Code Chapter .................C.............C......C..R. Title General Code Section ............191...... Revised Statutes Section .. HOW TO CITE OHIO STATUTES R........... the following abbreviations apply: OHIO STATUTE CITATION ABBREVIATIONS Revised Code Section .....SECTION THREE: STATUTES AND ORDINANCES ______________________________________________________ 3..” is not repeated before “4511.............191.....S.C..... 3905....... R.... and titles When citing an Ohio statute... Chapter 2901..C.. begin with the appropriate abbreviation listed above.......R.......... A... followed by the section number...... Chapter Revised Code Title ....... Abbreviations When citing an Ohio statute..03(B)..... chapters.......12..................C.......G........C.... R.....................R........” R..... Section numbers...... Chapters 5739 and 5741....... R...1... R. 4921......C..... Title 29....... NOTE: There is no period after the chapter number....

565. 1201. 3017. 133 Ohio Laws. 1. 2964.C. Part III.Sub. 136 Ohio Laws. 1524. cite the year of enactment: HOW TO CITE LEGISLATIVE ACTS – NO OHIO LAWS CITE 2011 Am. 646. R. 4123.B. No.C. Am.H.H. C. Part I.H. No.HOW TO CITE OHIO STATUTES (CONT.B.10. 653-656. repealed in Am. 2323.57(C)).S. No. When an Ohio Laws cite is not yet available. No. 257. 1465-80 (predecessor section to R. No. Part II. Am. G. division (B). 137 Ohio Laws.B.H.B. NOTE: The word “division” does not begin with a capital letter. Section 5.Sub. 268. The Supreme Court of Ohio 42 Writing Manual .C. 3020.) G.B.C. 126 Ohio Laws 730. Legislative acts An act may be designated as follows: HOW TO CITE OHIO LEGISLATIVE ACTS Am.Sub.

Federal Statutes. NOTE: Use a plural verb following the et seq. HOW TO CITE FEDERAL STATUTES 26 U. Place the elements of the citation in the following order: • • • The title number. Columbus Traffic Code 2133.S. 3. Cite municipal ordinances as shown in the following examples: HOW TO CITE OHIO MUNICIPAL ORDINANCES Cleveland Codified Ordinances 693. Akron City Code 432. Cincinnati Municipal Code 910-9. 2400.. Cite the United States Code.3. Codified Ordinances of the City of Cleveland. U.3.C.C.2. 42 U.C. The section number.S. 5 U. 551 et seq.C.07.S. in the above example The Supreme Court of Ohio 43 Writing Manual . 1983.16. are controlling. Ohio Municipal Ordinances.S.01(C).

........... Title 7.........Rev...................... Conn......073.............. use the following abbreviations: OUT-OF-STATE STATUTE CITATION ABBREVIATIONS Statute(s) .30.........Comp... Cite out-of-state statutes as shown in the following examples: HOW TO CITE OUT-OF-STATE STATUTES Ala..3.Stat. Cal............................ Chapter 122.... NOTE: This style is used when clarity requires the effective date of the statute...... Cal.Ann.........Civ.Comp.......Code Ann......07. Annotated ....Ann....Stat.......... Revised .......Laws Ann..Ann...Stat.. Out-of-State Statutes........ 13-1703......... effective June 10...4.Code 11-42-6. NOTE: “Chapter........Ann... 4-187.. Ill....” “Code...990... When citing out-of-state statutes...... Chapter 500... NOTE: A section symbol (§) is not used.....Stat..Code 1785.....Ann...Penal Code 1103a......Rev.. 1990......Rev........... NOTE: “Chapter” is preceded by a comma... NOTE: “Title” is preceded by a comma.....Stat.. Alaska Stat. Ariz. The Supreme Court of Ohio 44 Writing Manual .Gen.....................” and “Title” are not abbreviated..... Compiled . Mich......... Del. 47........ 177...... Ky..

Codified Laws 21-27-1.Water Code Ann. Miscellaneous Foreign Statutes.519.HOW TO CITE OUT-OF-STATE STATUTES (CONT. 161. 3. 11 Eng.5.Banking Law 380-h. Chapter 16. The Supreme Court of Ohio 45 Writing Manual . 55. Cite foreign statutes as shown in the following example: HOW TO CITE FOREIGN STATUTES Statute of Anne (1705). Section 27.) N. S.Stat.D. Tex.Y.

The Supreme Court of Ohio 46 Writing Manual .

R..3 Crim...2 C... 303. 34 CLE Reg.C. 2 and 10 Disciplinary Rules of the Code of Professional Responsibility……. Rules of Civil Procedure………………… Staff Notes to Rules of Civil Procedure….R.....R.R... Abbreviation App....Cond. Not abbreviated Rules of the Code of Judicial Conduct…. 11 Crim.. Cite Ohio rules of court as follows......... 601 Evid.. Rules of Criminal Procedure……………..... Ohio Rules.....Reg.... 56(C) 1994 Staff Note...R....1.. 4 Civ.... DR 1-101(A)(2) EC 1-1 and 9-3 Evid... Continuing Legal Education Regulations..1.R...R...R.. Rules of Evidence……………………….R. There is no need to precede the citation with the word ―Ohio‖ unless the context does not make it clear....... 10(A) Canon 8 of the Code of Judicial Conduct.. 9 Rules and Regulations Governing Procedure on Complaints and Hearings Before the Board of Commissioners on Grievances and Discipline………………………………… BCGD Proc. Jud..... 803 and 804(B)(5) The Supreme Court of Ohio 47 Writing Manual .....SECTION FOUR: RULES AND REGULATIONS ______________________________________________________ 4. Ethical Considerations of the Code of Professional Responsibility……... Rules of the Court of Claims…………….. RULE NAMES AND THEIR ABBREVIATIONS Rule Name Rules of Appellate Procedure……………. Civ..

R.R.Prac... 2(E)(4) Sup. HOW TO CITE LOCAL RULES OF COURT Loc. V Rules of Juvenile Procedure…………….. Prof.. 23 UPL Reg. Co. Rule XXVI of the Butler County Probate Court Rules of Practice.g.R.Ct.. Traffic Rules…………………………….___.RULE NAMES AND THEIR ABBREVIATIONS (CONT.R.. V(4)(G) Gov.R..R. Use the preferred short form of citation if the local rules of court set forth a preference. E.. Ohio Local Rules of Court.) Rule Name Supreme Court Rules for the Government of the Bar………………. 1.3(A) (current format) Supreme Court Rules for the Reporting of Opinions…………………… Rules of Superintendence……………….R.. 21 Mayor‘s Court Education and Procedure Rules……………………………………… May.R. 1(H)(2) 4. Unauthorized Practice of Law…………….. Rules of Practice of the Supreme Court…. the Local Rules of Practice and Procedure for General Division of the Montgomery County Common Pleas Court may be cited as ―Mont.R..Cond.Rep.Jud.Bar R. C. S. 43 Traf.Ed..R.C.Ct. Victims of Crime Compensation Rules…. R.. The Supreme Court of Ohio 48 Writing Manual .C.. VI(3)(A) (old format) S. General Division. 6.Op.4(a) S. follow the examples below.Ct. Juv. Abbreviation Gov. 15 of the Court of Common Pleas of Cuyahoga County..R. 400(F) V.‖ When no preference is stated.Prac.2. 3 Rules of Professional Conduct…………. Supreme Court Rules for the Government of the Judiciary……………. P.

. effective Feb.Crim. 4.R. Fed. Ohio Regulations..Code 5705-3-07(B).Code 4901:1-7-01 et seq.Code 109:4-3-09. Fed. Fed.P.P. 2 Federal Rules of Evidence…………………… Fed.Evid.Civ. 1990-1991 Ohio Monthly Record 1067. Use the following abbreviations in citing federal rules: FEDERAL RULE ABBREVIATIONS Rule Name Abbreviation Federal Rules of Appellate Procedure……….4.R. 12(a) Fed..R. Federal Rules of Criminal Procedure………. Cite Ohio regulations as shown in the following examples: HOW TO CITE OHIO REGULATIONS Ohio Adm.Bankr. Former Ohio Adm.R.P. 1977-1978 Ohio Monthly Record 3977.P. 48 Federal Rules of Civil Procedure……………..R. Ohio Adm. 7041 4.3.4.” Ohio Adm. Federal Rules.App.Code 3745-1-05. 1978. 411 Federal Rules of Bankruptcy Procedure……. NOTE: The word “Section” is not inserted after the word “Code.. The Supreme Court of Ohio 49 Writing Manual .

53 Fed. NOTE: C.F.Reg.R.F. Cite federal regulations as shown in the following examples: HOW TO CITE FEDERAL REGULATIONS 16 C. 545.Reg.4. 24440. NOTE: Fed. effective June 26.R.F. 52 Fed. The Supreme Court of Ohio 50 Writing Manual . 23967. 101. 1987. 113.Reg.5. = Federal Register Former 29 C.14.8-3(f).R. = Code of Federal Regulations 12 C.R.F. Federal Regulations. 23970.

Treatises.1. The title of the source. followed by a comma.SECTION FIVE: SECONDARY SOURCES ______________________________________________________ 5. preceded by the word ―Section‖. 1 Restatement of the Law 2d. and Dictionaries. at 20 (Tent. place the elements of the citation in the following order: • • • The volume number. The last name or full name of the author(s) of the source. When citing a Restatement. HOW TO CITE RESTATEMENTS 1 Restatement of the Law 3d. 1 Restatement of the Law 2d.‖ etc. 4 Restatement of the Law 2d. 1 Restatement of the Law 2d. The Supreme Court of Ohio 51 Writing Manual . Section 168. place the elements of the citation in the following order: • • • • • The volume number. Foreign Relations. Agency..2. or dictionary. Section 187. Torts. (1981). followed by a comma. Contracts. at 561 (1971). Misrepresentation. Section 895C(2)(b). if the Restatement has more than one volume. etc. Comment a (1965). NOTE: Do not use a page number when citing the section in general. NOTE: Use a page number when citing a specific passage or when quoting.). 5. The title of the Restatement (Contracts. When citing a text. Restatements. treatise. Conflict of Laws. Torts. followed by a comma. The section number.Draft 1967). Section 159 et seq. Do not use a page number when citing a comment. if the source has more than one volume. The phrase ―Restatement of the Law‖ or ―Restatement of the Law 2d. Section 111 (1986). Contracts. followed by a comma. NOTE: The letter designating the comment is no longer italicized. The year. refer to the most recent edition. within parentheses. Generally. Texts. if one is named. in italics.

1 Ohio Jury Instructions. Section 16. and dictionaries. The Supreme Court of Ohio 52 Writing Manual . Section 4. at 15-29 (3d Rev. 1 Jones. Section 5. Section 4.Gard Rev.Ed. at 907-909 (3d Ed. include the number inside the parentheses before the year. at 44 (1997). Section 15. NOTE: Do not use an ampersand character in the titles of texts. Use the word “to.1. do not use a dash to indicate a range. TREATISES. Dobbs. Eminent Domain. Section 1741A. as in this example.2003). LaFave.10. Law of Workers’ Compensation.45. within parentheses. preceded by a comma.g.55. Webster’s Third New International Dictionary 1203 (1986). Black’s Law Dictionary 101 (8th Ed. at 14-778 to 14-779 (1997). 3 Moore. Evidence.2009).2004).1. Ohio Real Property Law and Practice.1996).1996). 102-103 (1981).1997).Cleary Ed. Federal Practice. HOW TO CITE TEXTS. at 266 (3d Rev. Evidence. The year. Section 77. NOTE: When the source numbers its pages with hyphens.1(b) (3d Ed.1966). Search and Seizure.1984). if desired. Insurance Law and Practice.13.04[2]. If the volume is later than a first edition.Ed. e. Section 5071. Section 324. 3 Wayne R.1990). Section 7. (2d Ed. AND DICTIONARIES 8C Appleman. 4A Nichols.1972). 2A Larson. 25-26 (5th Ed. The page number.• • • The section number. Keeton.13[2] (2d Ed. Keeton & Owen. 5 McQuillin. treatises. Municipal Corporations. 2 Thomas McDermott. at 377 (6th Ed. Prosser and Keeton on the Law of Torts. Paragraph 15. Chicago Manual of Style 656 (15th Ed.1984). at 815 (3d Ed.” McCormick.

The last name or full name of the author(s). use Westlaw‘s or Lexis‘s abbreviations for sources.1995). Elements of citation When citing a law review article. in italics. The page number.3. Punitive Damages Should Be Abolished. 97 (4th Ed. 775 (1989).L.1961).Rev. Evidence. The Supreme Court of Ohio 53 Writing Manual . In general. Quigley. 8 Wigmore. 39 Case W. within parentheses. at 242-249 (Chadbourn Rev.L. Title and source The title of an article or note is italicized. Uniform Commercial Code. A.Rev. Ingram.Rev. Law Reviews. The volume number of the law review. place the elements of the citation in the following order: • • • • • • B.Res. HOW TO CITE LAW REVIEWS Steinberg. Ohio’s Unique Rule on Burden of Persuasion for Self-Defense: Unraveling the Legislative and Judicial Tangle. 7 Wigmore. using Westlaw‘s or Lexis‘s abbreviations.HOW TO CITE TEXTS. Section 2-7. 20 U. Section 1986. The year.U. TREATISES.) White & Summers.L. 5.1981). Sections 2380-2381 (McNaughton Rev. 205 (1988). 17 Cap. followed by a comma.Tol. including student authors. 105 (1988). The title of the article. AND DICTIONARIES (CONT. The name of the law review. followed by a comma. Economic Perspectives on Regulation of Charitable Solicitation. Evidence.

Cin. 727 (1960). NOTE: Use the name of the student author. 692. and the Judicial Process.L. Marinelli.U. 90 (1973). 26 U. Is America Over-Lawyered?.Rev. 50 Ohio St. 309 (1989). The Supreme Court of Ohio 54 Writing Manual .U. Hochman.L. Nagel. fn.L. 791.St. 16 Ohio N.L. 371.Rev. Please Don’t Read the Title. Microcomputers. Banner. 1 (1989). Note. Collateral Estoppel in Criminal Cases: Reuse of Evidence after Acquittal. 796 (1972). Miller & Leasure. 59 Ark.HOW TO CITE LAW REVIEWS (CONT.Rev.Rev. Accountants’ Liability to Third Parties. 22 Akron L.) Poulin. The Use of the Future Test Year in Utility RateMaking. 11. 14 U. 696.Fla. 31 Cleve. 107 (1988). The Supreme Court and the Constitutionality of Retroactive Legislation.Rev.Rev. 373 (1982).L. 73 Harv. 89.L. 243 (1989). 58 U. 1 (1989). Clark Evans Downs. 52 B. 43 (2006).Rev.Rev. Post-Kelo Determination of Public Use and Eminent Domain in Economic Development Under Arkansas Law.J. Civil RICO: The Legal Galaxy’s Black Hole. Judith Goldstein Korchin. NOTE: First name of author may be used.L. Systems Analysis. Morgan.L.Rev.Dayton L. Hufstedler.

Cite encyclopedias as shown in the following examples: HOW TO CITE ENCYCLOPEDIAS 22 American Jurisprudence 2d. 47 Corpus Juris. Damages.R.R. Section 271. 584 (1972) or Annotation.1986).3d 578. 448. Annotation.L. 5. Assault and Battery. Abraham Lincoln. 584 (1972). NOTE: Do not use an ampersand character in topic titles. 6 American Jurisprudence 2d. 24A Corpus Juris Secundum. 20 A. Section 3 (1974). Annotations.R.Fed.1983).5. 38 A. 38 A.3d 1384 (1971). NOTE: American Jurisprudence 2d is not abbreviated.4. Encyclopedias.3d 578. HOW TO CITE ANNOTATIONS Annotation.3d 1384 (1971). Section 321.R. Annotation. NOTE: Corpus Juris is not abbreviated. 46 A.L.L. ―Annotation‖ is not abbreviated. Sections 1748-1750 (1962. 27B Corpus Juris Secundum.5. Partition. or Annotation. at 337-338 (1929).R. at 656-657 (1959). Rights in Respect of Engagement and Courtship Presents When Marriage Does Not Ensue. Section 168. Supp.1983). Section 107 (1963. Divorce. Attorney’s Fees in Class Actions. Supp. 369 (15th Ed. 46 A. Criminal Law. 454. The title of an annotation is italicized but is not surrounded by quotation marks. The Supreme Court of Ohio 55 Writing Manual . at 367 (1965).L. 7 Encyclopedia Britannica.L. NOTE: Corpus Juris Secundum is not abbreviated.

Desperate to Cut Costs. No. Townships and Municipal Corporations. NOTE: When citing a supplement or pocket part. Cite nonlegal magazines and newspapers as shown in the following examples: HOW TO CITE NONLEGAL MAGAZINES AND NEWSPAPERS Thomas. Cleveland Plain Dealer (Mar. Business Week (Mar.HOW TO CITE ENCYCLOPEDIAS.6. 5. No. at 371 (1980). The Supreme Court of Ohio 56 Writing Manual . 2011-003. Wall Street Journal (Mar.Gen. Columbus Dispatch (Mar. Condominiums and Co-operative Apartments.CONT. 2. 5.7. Mehring. Cash Registers Are Ringing Online. 74-094. Federal Election Fund-Raising Rules Relaxed. 2007) 24. 2.Gen.1983). 2011 Ohio Atty.Ops. 2007) 50. 2. Cite Ohio Attorney General opinions as shown in the following examples: HOW TO CITE OHIO ATTORNEY GENERAL OPINIONS 1974 Ohio Atty. use the above three examples. 2007) 6. Section 809. Ohio Attorney General Opinions. McCraken.Ops. 21 Ohio Jurisprudence 3d. 26. 5. Kuhnhenn. 2007) A12. Ford Gets Union’s Help. 16 Ohio Jurisprudence 3d. Newsweek (Feb. Nonlegal Magazines and Newspapers. Building the Future. Counties. at 2-382. Section 20 (1979. 2007) A2. Supp. Ties of Blood & History. NOTE: Ohio Jurisprudence is not abbreviated.

bartleby. followed by a comma. at Thomas Paine.churchill-societylondon.ohiolap.ohioic. The name of the entity sponsoring the site need not be given if it is obvious from the URL. Notice of https://www. the date of publication of statistical information published only online might not be known or important. In parentheses.html (accessed May 1. Signs and Symptoms of Chemical Dependency. Part III (1776). the date accessed or date updated.uk/Munich. A full Internet citation includes: • • • • • Author (human or institutional) or sponsor or owner of the website. The date of publication in parentheses.org. 2009).org/Signs%26Symptoms. The Supreme Court of Ohio 57 Writing Manual . 2009). 5. The title. speech to the House of Commons (Oct. followed by a comma.com/133/3. HOW TO CITE INTERNET SOURCES Ohio Lawyers Assistance Program.8. available http://www. NOTE: Not all the citation elements set forth above are always necessary. The URL. http://www. http://www. Internet.5.htm (accessed Apr. 2009). 22.com/index. 2009). For example. Industrial Commission Form IC-12.html (accessed May 1.html (accessed May 3. available at the Churchill Society. Common Sense. Winston Churchill. in italics. 1938). Appeal.

The Supreme Court of Ohio

58

Writing Manual

SECTION SIX: MISCELLANEOUS CITATION RULES ______________________________________________________
6.1. Short-form Citations. A. Generally

Short-form citations are used when a source is cited more than once; the full cite is given when the source is first cited and a short form thereafter. The short form generally uses a few identifying words from the full caption. There are no strict rules; how much of the caption to leave out is discretionary. The writer may decide to use only the plaintiff‘s name or the whole caption as a short form. If the plaintiff‘s name is lengthy (e.g., Cambridge Commons Phase II Ltd. Partnership), a partial name could be used, such as Cambridge Commons. A defendant‘s name may also be used (e.g., Schiller as a short form for Mendoza-Hernandez Heating & Cooling Co., Inc. v. Schiller). It is advisable to avoid common names such as Smith or common parties such as a governor or prison warden in a short-form citation. B. Information within a short-form citation

Provide enough information in the short-form citation—or within two paragraphs preceding it—for the reader to find the case in the official reports. If the volume number of the case is not cited within a paragraph or two of the short citation form, include it in the short-form citation. This saves the reader from having to shuffle through pages looking for the volume number. C. Short-form citations for cases that have no WebCite

When a citation includes the official volume number, do not repeat the official volume number when citing the same case if fewer than two paragraphs separate the first and second citation. If the official volume number is omitted, the parallel citation should also be omitted. The year is generally not repeated.

HOW TO USE SHORT-FORM CITATIONS WITH NO WEBCITE Long form: Van Fossen v. Babcock & Wilcox Co., 36 Ohio St.3d 100, 522 N.E.2d 489 (1988). Short forms: Van Fossen.
The Supreme Court of Ohio 59 Writing Manual

HOW TO USE SHORT-FORM CITATIONS WITH NO WEBCITE (CONT.) Van Fossen v. Babcock & Wilcox Co., 36 Ohio St.3d at 116, 522 N.E.2d 489. Van Fossen at paragraph one of the syllabus. Short form within two paragraphs after official volume number: Id. at 116 or Van Fossen at 116. Short forms appearing more than two paragraphs after official volume number: Id., 36 Ohio St.3d at 116, 522 N.E.2d 489. Van Fossen, 36 Ohio St.3d at 116, 522 N.E.2d 489. But not: Van Fossen at 116, 522 N.E.2d 489. D. Short-form citations for cases with a WebCite

For short-form citations of cases with a WebCite, follow the same guidance as in the previous guideline, except use paragraph numbers instead of page numbers for pinpoints and include the WebCite when parallel citations are needed.

HOW TO USE SHORT-FORM CITATIONS FOR CASES WITH A WEBCITE Long form: Bonacorsi v. Wheeling & Lake Erie Ry. Co., 95 Ohio St.3d 314, 2002-Ohio-2220, 767 N.E.2d 707. Short forms appearing within two paragraphs after official volume number: Bonacorsi at ¶ 19. Bonacorsi at syllabus.

The Supreme Court of Ohio

60

Writing Manual

Comment g. Short form: 1 Restatement. Short form: White & Summers.1995). E. at 897.Rev. 2002-Ohio-2220.3d 314. 9 Lewis & Clark L. 95 Ohio St. 9 Lewis & Clark L. at 97. Section 288A. Uniform Commercial Code. Section 2-7.E. Short-form citations for sources other than cases Use the following examples for short-form citations of sources other than cases. 897 (2005). 879. Section 288A.Rev.2004). Torts. Do not use supra. Long form: 1 Restatement of the Law 2d.) Short form appearing more than two paragraphs after official volume number: Bonacorsi. Short form: Black’s at 1001. The Medical Marijuana Case: A Commerce Clause Counter-Revolution?. Section 2-7. Comment g (1965). 97 (4th Ed.2d 707.HOW TO USE SHORT-FORM CITATIONS FOR CASES WITH A WEBCITE (CONT. 767 N. Short form: Pushaw. Long form: Pushaw. HOW TO USE SHORT-FORM CITATIONS FOR SOURCES OTHER THAN CASES Long form: White & Summers. Long form: Black’s Law Dictionary 1001 (8th Ed. The Supreme Court of Ohio 61 Writing Manual . at ¶ 12.

4th 782. Validity. Short form: 22 American Jurisprudence 2d at 367. Long form: 3 LaFave. Property and Freedom: The Constitution.HOW TO USE SHORT-FORM CITATIONS FOR SOURCES OTHER THAN CASES (CONT. Section 7.R. Law of Workers’ Compensation 14-778 to 14-779 (1997). Short form: Siegan. and Application of State Statute Requiring Doctor or Other Person to Report Child Abuse.L. Section 7. Long form: 2A Larson. Long form: 22 American Jurisprudence 2d.L.L. Short form: 73 A. and Land-Use Regulation 18 (1997).R. the Courts. 73 A.4th at 789-790. 789-790 (1989). Short form: 3 LaFave at 442. Short form: 2A Larson at 14-778 to 14-779. Section 271.) Long form: Annotation.1(b).R. Search and Seizure. Long form: Siegan. Construction. The Supreme Court of Ohio 62 Writing Manual . 789-790 (1989) or Annotation. Damages. at 367 (1965).1(b).1996). at 442 (3d Ed.4th 782. 73 A. Property and Freedom at 18.

For example.. A. see generally The Supreme Court of Ohio 63 Writing Manual . Definition Signals are words and phrases that are used to introduce legal authority.g. see see also see. e. C.g.2. Certain signal words and phrases use commas as indicated in the examples below.. Signal Words. a citation may be intended to provide the reader with authority that contradicts a particular statement. They tell the reader why a source is being cited when the citation serves a purpose other than direct support. Style The first letter of signal words should be capitalized only when they begin a citation sentence. B. Common signals The following are common signal words and phrases: COMMON SIGNAL WORDS AND PHRASES accord but see compare compare … with contra e. The signal contra alerts the reader to that fact.6. Signal words and phrases are italicized.

6 Ohio St. 698. 15 Ohio St. In other words.. 359 (1788).g. e. White.2d 749 (1982).E. see generally State v. Co.Rptr. Eriksson Eng. As the examples below suggest. 442 N. No signal Use no signal before a citation when the citation provides direct support. 8 Ohio St. Ltd. 39 Ohio St.3d 26. Use of signal words When a case or other authority is cited as the source of a quote or as direct support for a statement. 457 N. when using a signal word. however. v.E. Accord Superior Uptown. 313 N. 239 N... 141 Cal.2d 146. In other situations.E. 2 T. 20 Cal.3d 150.E.HOW TO USE COMMON SIGNALS See Haverlack v. v. Men of Devon. citing Russell v.2d 36. 1. contradicts it. Portage Homes. when a citation provides indirect support for a statement. The Supreme Court of Ohio 64 Writing Manual .R. Honeycutt.3d 31. Cleveland. 672-673. 2 Ohio St.2d 312 (1983). D. use no signal when you are quoting or paraphrasing language from the source or you are identifying a source referred to in the text. 33.2d 1050 (1977).2d 65 (1968). or provides a useful comparison—signal words are used to explain the level of support or contradiction that the cited authority provides. paragraph two of the syllabus. People v. consider including a parenthetical that clarifies why the case is being cited and why the signal is appropriate. Barker. e. 667. See also Enghauser Mfg.Rep. no signal word is necessary. Inc. Inc. 40-41.g. 100 Eng.3d 39. See. 570 P.E. 451 N. see also State v.2d 228 (1983)..2d 820 (1974).

v. 368. 881 N. the commissioner‘s determination is presumed to be correct.E. paragraph one of the syllabus (―The Board of Tax Appeals has control over its decisions until the actual institution of an appeal or the expiration of the time for an appeal‖). Accord Natl. See is the appropriate signal. Levin. ¶ 16 (the taxpayer bears the burden ―to show the manner and extent of the error in the Tax Commissioner‘s final determination‖ and to demonstrate that the commissioner‘s findings are ―clearly unreasonable or unlawful‖). Cincinnati School Dist. such authority does not extend beyond institution of an actual appeal or expiration of the time for appeal. HOW TO USE SEE When a taxpayer appeals a determination of the commissioner to the BTA. See Use See when the citation provides clear support for the proposition. 152 Ohio St.2.2d 227. See‖ above). HOW TO USE ACCORD While boards of revision have inherent authority to reconsider their own decisions since the power to decide in the first instance carries with it the power to reconsider. 117 Ohio St. Inc. 87 Ohio St. 89 N. but the support is indirect. 3. Bd. 2008-Ohio-68.E. The Supreme Court of Ohio 65 Writing Manual .3d 4. 721 N. of Revision. v.2d 129 (1949). 4.E. Accord After citation or discussion of a source. Bd. See also Use See also to indicate additional sources that provide indirect support for a proposition (see ―2. Ayres.3d 363. 255. of Edn.2d 40 (2000). use Accord to introduce citations of one or more additional sources that provide direct support for the same proposition. v. See Shiloh Automotive. If inference is necessary because the source does not state the proposition explicitly. Hamilton Cty. and the taxpayer must shoulder the burden of rebutting that presumption. Tube Co.

Hobbs. failed to pay any support for more than a year. .g. e. see also Skeens. R. at *4 (defendant‘s prior acts of violence and threats toward his wife were admissible because they were directly relevant to her belief that he intended to cause her physical harm). Horsley at ¶ 27. 20. 1999 WL 668799. the trial court did not abuse its discretion in admitting evidence of appellant‘s other prior threats and acts of physical violence. Compare is used alone. 2305. Compare In re Adoption of Canter.‘s testimony was relevant to prove the essential elements of appellant‘s menacing-by-stalking charge and not otherwise unfairly prejudicial to him. Furthermore. An explanatory parenthetical is recommended.07 does not define the time at which a claim for unjust enrichment accrues. HOW TO USE COMPARE Unlike other statutes of limitations. Cf. where Cf. No. 1999) (noting that ―[w]hile appellee‘s contribution to Stetson‘s support * * * may have been minimal.HOW TO USE SEE ALSO Because M.09 (providing that a claim for the wrongful taking of personal property does not accrue until the wrongdoer is discovered). follows court analysis). 2305. Hobbs received income in excess of his total support obligation. Compare Use Compare alone if the second citation follows a discussion of a cited authority (or.. Instead use Compare in a variation on the Compare . explained below. 5. 6. with signal.C. . 1999 WL 1082658. at *4 (Aug. Compare R. in an opinion. Do not use Cf. including prior conviction for telephone harassment. is relevant and properly admissible to prove essential elements of menacing-by-stalking charge). 29 (evidence of past conduct toward victim. 5th Dist.C. would have been used. See. however. food and shelter were paid for by the state due to his incarceration. Unlike the father in Masa. The Supreme Court of Ohio 66 Writing Manual . the evidence clearly established that appellee did not fail to provide support and maintenance to such a degree as to equate to abandonment‖).B. 98-CA-5.

in determining the best interests of the child).2d 847 (2d Dist.E. 3937.1996). Chapter 2744.7. 18269. HOW TO USE CONTRA If ―evidence [is] presented on almost every factor‖ listed in R.C. that is ―sufficient to indicate that a trial court adequately considered the best interest of the child. Contra Use Contra when the cited authority directly contradicts the stated proposition. 115 Ohio App. 3937. 9th Dist. 685 N.C. 8.18 with former R.C. HOW TO USE COMPARE…WITH The 2001 statute eliminated the requirement in former R. But see Use But see when the cited authority indirectly contradicts the stated proposition. Compare…with Use Compare . Dilworth. 1997). Part V. But see is used where see would be used to show indirect support.18(A) that insureds must be ―legally entitled to recover‖ from their tortfeasors and the provision that coverage is not precluded when the tortfeasor is statutorily immune from liability under R. . contra Dilworth v.18(A)(1).C. 3937. 148 Ohio Laws. 3901. No. 9. The Supreme Court of Ohio 67 Writing Manual . An explanatory parenthetical is recommended. 5.3d 537.‖ In re Roberts. 1 (interpreting the General Assembly‘s use of the word ―shall‖ in the statute as mandating that the trial court consider all of the enumerated factors. with to compare two or more citations in sequence.04(F)(1). 11380. as well as all other relevant factors. Compare R. fn. An explanatory parenthetical is recommended. 11380-11381. 1997 WL 76096.C. . at *3 (Nov. 542.

.3d 98.3d 87.g.E. See generally Use See generally to introduce helpful background authority. no court would admit a statement made eight months after the event. ¶ 24 (finding a statement made after one week admissible). 170 Ohio App.R. 11.2d 1128 (1985).1 as constitutional). See. is an effective way to avoid string cites. See generally State v. 12.g. 2004-Ohio6478..1 provides that if a defendant fails to notify the court in writing that he intends to claim alibi. days. The Supreme Court of Ohio 68 Writing Manual . but see Butcher. paragraph one of the syllabus (upholding Crim.R.g.E. Accurate use of e.3d at ¶ 29-34 (finding statements made after two months were inadmissible as an excited utterance). CA2003-09-228. E. 599 N. the court may exclude alibi evidence unless the interests of justice require otherwise. No. 90-91. is always followed by a comma. State v. when the cited authority directly supports the proposition and is representative of several authorities that are not cited. 477 N.. Nitz. E. Wallace. 10.HOW TO USE BUT SEE While courts have admitted statements made after several hours.g. or even weeks. 12. which are generally disfavored. 17 Ohio St. Smith.g. e. HOW TO USE SEE GENERALLY Crim.2d 124 (1988) (finding that a statement made after 15 hours was admissible). State v. 12th Dist. Use E. 37 Ohio St.

312. 152 N. e. While the contract did not specify exactly what words were needed to effect a cancellation. Citations Omitted. Use See. unequivocal. See. E. No. Spicer Constr. Use When citations are omitted from a quotation. Note the use of two commas. to indicate that the cited authority provides indirect support for the proposition that the cited authority is one of many that provide this same support. add the parenthetical explanation ―Citations omitted‖ immediately after the quotation. A.3d 391. The CSPA applies to contracts to build a home. 2001 WL 604226 (June 5. e. 665 N.. because these transactions involve the purchase of a service rather than simply the purchase of real estate. Capital-Plus. 6. Potter. Co.3. accounting documents established a paper trail of the personal loan coupled with the testimony of the corporate owner and the accountant).g... however. See.E. Benefit Assn.2d 162 (1950) (notice of policy cancellation need not be in a particular form but must be definite.. both parties could reasonably expect that any attempt to cancel would be clear and definite. of Ry. v. If ―Citations omitted‖ is used. 85 Ohio App.. Keiber v. before the citation. Place the period inside the parentheses. 392. ellipses to mark the omissions are unnecessary. e.. 10th Dist.E.. Emps.2d 414 (9th Dist. ―Citations omitted‖ is unnecessary.1993). See.g.HOW TO USE E.g. and certain).g. The Supreme Court of Ohio 69 Writing Manual ..G. The absence of loan documents does not create an issue of fact in the face of the undisputed testimony. 319-320. 153 Ohio St. 2001) (although no loan documents existed. E. Inc. 00AP-1353.G.. If ellipses are used to mark the omission of a citation. 12. e.g. Inc. HOW TO USE SEE.. Schwer v.

Explanatory Case History. rev’d. A. The use of this phrase obviates the need for an ellipsis inside the quotation. Do not omit internal quotation marks. It is not acceptable to use the parenthetical explanation ―Citations omitted‖ or ―Internal quotation marks and citations omitted‖ to excuse the omission of a citation for a quotation within a quotation. Thus.HOW TO USE CITATION OMITTED ―Usually.E.4. following the word ―quoting‖ (not ―citing‖).E. ¶ 26. Wilkins. evidence regarding the diminution in value is needed to determine the reasonableness of the restoration costs. Co. 108 Ohio St. Attribution of a quotation within a quotation If there is a quotation within a quotation. 2008-Ohio-5202. which the writer using this quote has deliberately chosen to omit. 120 Ohio St. 2005-Ohio-3720. NOTE: The original quoted material from Krofta cited a case after the first sentence. the parenthetical phrase “Citation omitted” appears directly after the closing quotation marks. or vacated on other grounds are italicized and abbreviated as shown. If a quotation is cluttered with pointless internal quotations. aff’d. Stallard.3d 127. No. Levin. 6. rev’d on other grounds. B.3d 90. The Supreme Court of Ohio 70 Writing Manual . paraphrase it instead of quoting it. 8th Dist.‘‖ Newman v. however.) Krofta v. HOW TO ATTRIBUTE AN INTERNAL QUOTATION A notice of appeal ―‗must explicitly and precisely recite the errors contained in the tax commissioner‘s final determination. 2005 WL 1707013.2d 995. Failure to present such evidence. quoting Cousino Constr. is not necessarily fatal to a claim in tort for damages to real property. overruled in part on other grounds. followed by commas. the internal quotation must be attributed. Style Explanatory terms such as overruled. 2006-Ohio162. 85369. ¶ 27. 840 N.2d 1065. either by quoting the citation provided in the original or by adding the citation after the primary citation. v. appeal dismissed. ¶ 41. 896 N.‖ (Citation omitted.

second motion for new trial denied. 732 (E. Lockett v.1968). 692.1967).Tenn. 22 L. aff’d.2d 48. 89 S. aff’d.Ct.3d 195.Ed.1960).S.Tenn. 692 (E. 358 N.Tenn. 57 L.E. ___ L. 349 F.2d 973 (1978). 2824. 310. United States.Ct.Ct.Ct. aff’g 182 F.3d 176.E. 908 N. 2006-Ohio6712. remanded sub nom. 87 S.E. 1163. 2008-Ohio-5200. 307 F. except for a very recent case. But see United States v. E. conviction and overruling of first motion for new trial aff’d. when the time for reversal has obviously passed. 586. ___. denied and appeal not accepted are useful in these two examples. vacation. 129 S.2d 621.1970). History affecting precedential value Always indicate any reversal. 98 S. 247 F.E. sub nom. 1964). State v.Supp. 120 Ohio St. in which the case is recent. 17 L.D.D.1967). Cert.2d 510 (7th Dist. 897 N. Ohio.Pa. Do not include any further history of a case unless it affects the case‘s precedential value. Cohen. 268 F.1967).1960).Supp.2d 1062 (1976). even if that subsequent action is based on other grounds.2d 1020 (6th Cir. or overruling.Ed.2d 297 (1969).S.2d 291 (6th Cir.2d 856 (6th Cir.D. 181 Ohio App. denied.D.1965).Supp. NOTE: Cert. 438 U.D. 408.Ed. 11989 (May 2. 284 F. rev’d on other grounds. fourth motion for new trial denied. cert.).S. No.B. 247 F. 112(E. 859 N. 65. 698 (E.2d 374 (1966). 398 F. 385 U.2d 20 (6th Cir. The Supreme Court of Ohio 71 Writing Manual . Morway v. HOW TO ADD AN EXPLANATORY CASE HISTORY State v. appeal not accepted.1965). aff’d. 2009-Ohio-932. 2954.Tenn.S. ___ U. Giordano v.3d 1478. 122 Ohio St. 394 U.2d 559. Veney.Tenn. Durkin. aff’d. Lockett. 608 (E. 382 F.Supp. Hoffa.Supp. Highway Truck Drivers & Helpers Local 107 v. do not record the denial of an appeal in a history line.2d 162 (3d Cir. 49 Ohio St.1965). fifth motion for new trial denied. NOTE: A history line this detailed is rarely necessary or helpful. Otherwise.Ed. denied is an example of subsequent history that has no effect on the authoritativeness of a case and is therefore not used. 293.D.2d ___ (2009). 376 F. third motion for new trial denied.

for contrast. Citations are best placed at the end of a sentence.).5. Avoid placing all citations in footnotes. The best way to include nonstatutory citations in text in a way that promotes readability is to put them in a separate citation sentence whenever possible. try to restructure the sentence to avoid the midstream citation. as it makes it difficult for the reader to connect the authority to the proposition. for background. has a court held that the dog‘s owner could recover from the victim.).6. Because nonstatutory citations contain so many abbreviations and numbers. Placement of Citation.2d 401. • • WHERE TO PLACE A CITATION Bad example: Ohio courts have addressed more than once the recovery of damages for injuries caused by a dog bite. When deciding where to place a citation. The entire point of citations and of the signal words or phrases preceding them is to communicate to the reader exactly which source is being relied upon and for what purpose (for direct support. strive for maximum readability using the following guidelines: • Citations offer support. ¶ 27 (3d Dist. makes a legal argument.E. or quotes or paraphrases language from a source. The Supreme Court of Ohio 72 Writing Manual . Only in McGuffin. 101 Ohio App. refers to a legal source. 301 N. The guidelines for citation style appear throughout this manual. If a sentence seems to require a citation in the middle.3d 201. A citation must be provided in support of any sentence in which the writer sets forth a statement of the law. etc. they are not very readable as part of textual sentences. 2004-Ohio-1. include pinpoint citations to refer the reader to the exact page or paragraph that supports the proposition. the case certified as conflicting with the decision of the court below. The practice of placing all citations in footnotes is disfavored. Often a sentence with a citation in the middle can be revised by simply extracting the citation from the center of the sentence and moving it to the end. When citing.

) Better example: There is only one known Ohio decision in which the court has held that a dog‘s owner can recover from the victim. B. Baty. and that case has been certified as conflicting with the decision of the court below: McGuffin v. The Supreme Court of Ohio 73 Writing Manual . Emphasis added. General Emphasis sic. Emphasis sic The term ―Emphasis sic‖ is used to indicate that the word or words emphasized with italics were also italicized in the original. the court granted a motion to strike a claim for lost wages brought by the dog‘s owner.) 12. Nickels v. (N. Better example: In an early dog-bite case. 4 Ohio Dec. A.3d 201. Emphasis Added. 2004-Ohio-1.). 1901 WL 101 (1901). (N. the court granted a motion to strike a claim for lost wages brought by the dog‘s owner. 1901 WL 101 (1901). Emphasis Sic. 301 N.S. Emphasis Deleted. 1 Ohio N. 101 Ohio App. after the ending quotation mark but before the citation. 4 Ohio Dec.) 12. Nickels v. 101. 101.2d 401.S. 6.6. ¶ 27 (2d Dist.P. Baty. 1 Ohio N. Hearst. All three appear in parentheses. and Emphasis deleted are three terms used to indicate that the immediately preceding quote has been altered to add or delete emphasis or to indicate that the emphasis in the quote was in the original.E.P. with a period inside the closing parenthesis and the word ―Emphasis‖ capitalized.WHERE TO PLACE A CITATION (CONT. Bad example: In an early dog-bite case.

E.2d 840 (1991).. 575 N.‖ (Emphasis deleted. HOW TO USE EMPHASIS ADDED The contract provides that ―the parties shall deposit $100 with the escrow agent.) NOTE: In the original opinion being quoted.HOW TO USE EMPHASIS SIC The contract provides that ―the parties shall deposit $100 with the escrow agent.) ―[U]nsupported conclusions are not considered admitted and are not sufficient to withstand a motion to dismiss.) NOTE: The period appears inside the parenthesis. the word “appellant” is in italics. The Supreme Court of Ohio 74 Writing Manual .3d 602. NOTE: The term “emphasis added” appears after the quote but before the citation. Ohio Adult Parole Auth. 603.) State ex rel.‖ (Emphasis added. D. HOW TO USE EMPHASIS DELETED This court concluded that ―any stay of an order of the commission is dependent on the execution of an undertaking by the appellant.‖ (Emphasis added. C. Emphasis added The term ―Emphasis added‖ is used to indicate that the word or words in italics were not italicized in the original. Emphasis deleted Use the term ―Emphasis deleted‖ to indicate that quoted material had an italicized word or phrase from which the italics have been removed.‖ (Emphasis sic. 61 Ohio St. Smith v.

1979).1976). United States v. Dayton.1977). B. Co. Liberty Mut.App. John. Prosser & Keeton.1984).6. In citations. 586 P. Davis.A.Ohio 1983). 689 (S.Supp. Ordinal numbers‖ and ―D. Spacing within Parentheses in Citations. Ins. 367 So. HOW TO USE UNABBREVIATED WORDS WITHIN PARENTHESES State v.E. 574 F.P. spacing within parentheses should comply with the following guidelines. Names of months‖ below. 343 N. Graley v. 562 F. A.D.2d 832 (C. C. Woods v..D.C. Ordinal numbers Ordinal numbers within parentheses are followed by a space.2d 658 (Fla. HOW TO USE ORDINAL NUMBERS WITHIN PARENTHESES Black’s Law Dictionary 826 (7th Ed.2d 681 (C. Unabbreviated words Unabbreviated words within parentheses are followed by a space. Abbreviated words Except as provided in ―C. The Supreme Court of Ohio 75 Writing Manual .1999). HOW TO USE ABBREVIATED WORDS WITHIN PARENTHESES Sullivan v. The Law of Torts.2d 410 (Utah 1978). abbreviated words within parentheses are not followed by a space.7. Satayatham. Section 80 (5th Ed.

D.

Names of months Names of months within parentheses are followed by a space, whether abbreviated or not.

HOW TO USE NAMES OF MONTHS WITHIN PARENTHESES Hearing v. Delnay, 10th Dist. No. 76AP-493 (Dec. 21, 1976). Tavzel v. Aetna Life & Cas. Co., 8th Dist. No. 53931 (June 16, 1988).

6.8.

Months of the Year.

In citations, the months of the year are abbreviated as follows:

ABBREVIATIONS FOR MONTHS OF THE YEAR January ................................ Jan. February ..............................Feb. March ..................................Mar. April. ...................................Apr. May .....................................May June .....................................June July .....................................July August ................................Aug. September ..........................Sept. October...............................Oct. November...........................Nov. December ...........................Dec.

6.9.

Abbreviations in the Style or Citation of a Case.

Use the following list of abbreviations when citing cases and in the cite-as line. Plurals of these words can, for the most part, be abbreviated by adding an ―s‖ before the point, e.g., ―Boards‖ is replaced with ―Bds.‖ If the abbreviation ends in ―s,‖ the abbreviation is the same for both the singular and the plural, e.g., ―System‖ and ―Systems‖ are abbreviated ―Sys.‖ If an abbreviation ends in ―y,‖ the plural form of the word must be spelled out, e.g., ―Counties‖ is not abbreviated.

The Supreme Court of Ohio

76

Writing Manual

ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE Accident ...........................................................................Acc. Administrative..................................................................Adm. Administrator (abbreviated in formal case caption) ..................Admr.
Note: Do not use “administratrix.”

also known as (abbreviated in formal case caption) ..................a.k.a. America, -n ......................................................................Am. and ....................................................................................& Apartment ........................................................................Apt. Associates .........................................................................Assoc. Association .......................................................................Assn. Assurance .........................................................................Assur. Attorney General (abbreviated in formal case caption) .............. Atty. Gen. Auditor (abbreviated in formal case caption)................................. Aud. Authority ..........................................................................Auth. Automobile ......................................................................Auto. Avenue .............................................................................Ave. Board ................................................................................Bd. Boulevard .........................................................................Blvd. Brotherhood .....................................................................Bhd. Brothers ............................................................................Bros. Building ............................................................................Bldg.

The Supreme Court of Ohio

77

Writing Manual

ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE (CONT.) Bureau ..............................................................................Bur. Casualty............................................................................Cas. Center ...............................................................................Ctr. Central ..............................................................................Cent. Chemical ..........................................................................Chem. Civil..................................................................................Civ. Commission .....................................................................Comm. Commissioner ..................................................................Commr. Committee ........................................................................Commt. Company ..........................................................................Co. Compensation ..................................................................Comp. Consolidated ....................................................................Consol. Construction .....................................................................Constr. Contractor ........................................................................Contr. Cooperative ......................................................................Coop. Corporation ......................................................................Corp. Corrections, -al .................................................................Corr. County ..............................................................................Cty. Department .......................................................................Dept. Development, -al ..............................................................Dev.

The Supreme Court of Ohio

78

Writing Manual

................. Division ...... The Supreme Court of Ohio 79 Writing Manual ....................................Fed................................. East....................................... District.....................) Director (abbreviated in formal case caption) ..... Executor (abbreviated in formal case caption) ..........................Exr.........Equip...................................................... Federation .............................Ent.........................................................................................a..................Emp...... Footnote ..................................................................................................................................................b......................Div........................... Employee.......................... -ion.. Electric............ Fidelity ...... Dir........................... doing business as (abbreviated in formal case caption) ...............................Distrib............................Edn. Foundation .....fn................Dist...................................................Fin................................ Distributor........... -ment.................. formerly known as (abbreviated in formal case caption) ....” Federal......... -al .Fid............Elec.....................Fedn................. -er..... Finance............ Equipment ...................... d............................... -ern ......... -ial ............ -ing ...................................... Enterprise .. Engineering ......E.....f.................. Education ..................Found.....ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE (CONT............... NOTE: Do not use “executrix...........k.......a........................................................Eng........................................................................

.....Hous..............Indus.....................................Guar........... -ion ........................ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE (CONT..........................Liab.................. Housing ...................................................................Illum......Inc......................Ins....... Independent ....Invest.............................Hosp........................ Heights ..............Gen... Government.........................................) General .......... Insurance ............................................................................................................................................................................ In the matter of ............ Industrial ..................................Govt........... Indemnity ............................. Illuminating .....................................................Indep......Inst..........In re International ...........Grdn.................................................................... Guaranty.......................Hts..... Incorporated .......................................................................................................... Investment ...................................................... Liability ........................................................................................................................Indemn................. The Supreme Court of Ohio 80 Writing Manual ............................................ Hospital ..........................Internatl............................................... Guardian (abbreviated in formal case caption)........................................................Hwy.......................................... Highway ................................ Institute.............

..........N......................................................................................................a.. Manufacturing ................................................................... Manager (abbreviated in formal case caption) .................................................................................................................................... Mgr.............................................Mgt. Market ........................................ The Supreme Court of Ohio 81 Writing Manual ................. Product................... -ion .................................ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE (CONT....... now known as (abbreviated in formal case caption) ...................................................Mkt...........................................................................Med........ Medical ...Mfr................... Memorial ...................................... Manufacturer ........ National ................Mun............................. Mount ...............................................Prod.................................... Number .. North..................................n........................Mt.. Metropolitan .........Natl........................................................................No..Mut................ Mortgage ....................Mfg......... Mutual ....................................................) Limited ............................................................................Metro...............................................................................Org..... Organization ..........Mem.........Mtge......................... -ern (except when part of state name) ... Municipal ......... Management ............Mach...... Machinery .........k..............................Ltd.......................

........................................... Public .............. Secretary (abbreviated in formal case caption) .........................................Res.............. Standard ...............Soc.............. Railway ............................. Railroad .......................................... Security .............................. Psychiatric ........Secy......................................................................................................... South................ The Supreme Court of Ohio 82 Writing Manual ..................) Prosecuting Attorney................................................. Society................ Sanitary ...............................................................................................RR................ Atty............St..................................Std....................... Review ...Refrig........................................ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE (CONT.............................. Road ......................................................................................................Sav.........Rehab................................ Rehabilitation ........Psych........... -ern (except when part of state name) ................ Refrigeration ...............................................................................................................Serv......................................S.... Service....S..........................................Sec.............Ry........................................................................... & L.................Pros................................................ Savings & Loan.... Reserve ....................Rev............................ Street ...........Pub...............Sanit. Savings .................................................................Rd...............................

............................................................................................................. at 14.. Torts (1965).... West....................Sur......................................... Utility and Utilities ......... when referring to the immediately preceding cited authority............................................................................... supra.............) Surety ............................................................. 6......... System .................10..‖ Id................. Telegraph ..............Unemp...............Twp.. Telephone ........... Transportation ........ Use of Id.........Transm............... The element of publication occurs when the defamatory matter is communicated either negligently or intentionally to anyone other than the person defamed....... 3 Restatement of the Law 2d.......................................... Id........... Unemployment .................. Transmission ............. Use Id.W.. HOW TO USE ID.......... University....Sys.... Haller held that ―a releasor ought not to be allowed to retain the benefit of his act of compromise and at the same time attack its validity...........................................Transp. and infra A......... Section The Supreme Court of Ohio 83 Writing Manual ..................2d 207..............Tel....... 552 N.......................... -ern (except when part of state name) ...................Tel......................ABBREVIATIONS IN THE STYLE OR CITATION OF A CASE (CONT.........Util..........E......Univ........... Township....

They should not be used to refer to textual material. at 201.HOW TO USE ID. See Grover.e. is not capitalized when it appears in midsentence. The Supreme Court of Ohio 84 Writing Manual . id. Id. 702 N.. do not write ―As we held supra.E. Any act by which the defamatory matter is communicated to a third party constitutes publication. 144 U.Rev. supra. at 43. i. – CONT. at ¶ 11. at Comment a. Punitive damages are not available in an ordinary negligence action. infra.‖ HOW TO USE SUPRA AND INFRA It is the trial court‘s responsibility to determine the admissibility of evidence.L. and appellants were not entitled to an instruction on that issue. B.‖ Write ―As we held above. Supra and infra The use of supra and infra is limited to citations. 577(1).2d 866. NOTE: Id. Getsy. Punitive Damages in Ohio.Tol.

PART II. STYLE GUIDE The Supreme Court of Ohio 85 Writing Manual .

The Supreme Court of Ohio 86 Writing Manual .

1991). The Elements of Style (4th Ed. one alternative has been chosen. The Handbook of Good English (Rev. When more than one correct standard or practice exists. The guide makes no attempt to be comprehensive. Johnson.2001). The Gregg Reference Manual (9th Ed. the Reporter‘s Office follows conventions of standard English and relies in particular on The Chicago Manual of Style (15th Ed.2000). A Dictionary of Modern Legal Usage (1995).2003). grammar. and Strunk & White.Ed. and usage that are not covered by this guide. diction. Sabin. The Supreme Court of Ohio 87 Writing Manual . For rules of punctuation.INTRODUCTION TO THE STYLE GUIDE _____________________________________________________ The Style Guide sets forth standard guidelines for formal English writing. Garner. hyphenation.

The Supreme Court of Ohio 88 Writing Manual .

justice of the Ohio Supreme Court. secretary of state the township trustees. even when they directly precede the name. Secretary Ellenberger. federal judge Ron Gage Justice Archer. Secretary of State Ellenberger. Capitalize only proper nouns. Chief Justice Rehnquist. 7. former governor John Landis the Wood County prosecuting attorney. Titles are not capitalized when used as appositives. Trustee Laski the chief justice.SECTION SEVEN: CAPITALIZATION _____________________________________________________ 7. Lowercase the title when it follows the name and when it is used in place of the name. the justices Gaston Puttemans.2. members included the common pleas court judge Lucien Fignon and the banker Bill Coates (appositives). Proper Nouns. judge of the Cuyahoga County Common Pleas Court. Phillip Archer. J. Emil Roelants. Governor John Landis. the tax Commissioner the governor.1. the commissioner. Marita Ellenberger.D. the board of trustees. governor of Ohio. mayor of Columbus the secretary of state. the former justice William Rehnquist. Judge Fignon. Commissioner Phelps. Capitalize a person‘s title when it is used immediately before the personal name as part of the name. attorney Puttemans Mayor Roelants.. chief justice of the United States Tax Commissioner Phelps. HOW TO USE CAPITALIZATION IN PERSONS’ TITLES Lucien Fignon. Prosecuting Attorney Fletcher The Supreme Court of Ohio 89 Writing Manual . William Rehnquist. Titles of Persons. Common Pleas Court Judge Lucien Fignon attended (title). John Landis.

the House. Agencies. Columbus City Council Brown Township. the Board of Trustees of Green Township the Cleveland police. the court the General Assembly. the city. the Brown Township Board of Trustees. and Entities. the Sixth District Court of Appeals. the court. the Ohio legislature. the Senate. the Ohio Supreme Court. the upper house the Court of Common Pleas of Franklin County. Capitalize full proper names of entities and certain short forms. the Supreme Court. the legislature. the Department of Education the Columbiana County Grand Jury. Perrysburg public schools. the United States district court the Court of Claims the Bureau of Workers‘ Compensation. HOW TO USE CAPITALIZATION IN PROPER NAMES OF ENTITIES AND SHORT FORMS the Erie County Court of Appeals. the police department.7. the common pleas court the United States District Court for the Northern District of Ohio.3. the board of education the State Board of Education. the Franklin County Common Pleas Court. the grand jury The Supreme Court of Ohio 90 Writing Manual . the Sixth District the Supreme Court of Ohio. the court. Public Offices. the school district. the court of appeals. the township board of trustees. the city council. the bureau the city of Columbus. the Cleveland Division of Police Perrysburg City School District.

NOTE: August is not abbreviated in the above example. put a comma after the year.. day. 2007. NOTE: There is no comma and no “of” between July and 1983. The building was completed in July 1983. 1963 agreement. and August 15. On February 2. When the date is a full one. a comma always follows the day. 14. was the date of the journal entry. If only the month and the year are used. See next example. the petitioner filed the first motion for protection. the appellant received the January order. 26 days later. and year. 1981. On July 7. do not use a comma or the word ―of‖ after the month. HOW TO USE DATES IN TEXT The journal was first issued on August 25. The plaintiff was not a party to the April 3. and year. from August 22.e. during the 1980-1981 school year since the 1950s The Supreme Court of Ohio 91 Writing Manual . 1973. A comma also follows the year unless (1) the date is being used as an adjective or (2) the year ends the sentence. August 14. NOTE: In a phrase of month. to December 1973 July or August 1977 The hearing was held on July 16. June 23. The hearing was held on March 13. and 15. day.SECTION EIGHT: DATES IN TEXT ______________________________________________________ Months are spelled out in text. month. 1980. 1948. 1984. NOTE: Do not follow a date used as an adjective with a comma. i. unless the phrase is used as an adjective.

The Supreme Court of Ohio 92 Writing Manual .

Spell out all numbers that begin a sentence.200 feet wide one million volts or 1.000. e. state‘s exhibit No. 1. assignment of error No. numerals may be used for all. 14-year-old girl The witness was 12 years old The parcel was 1.000. When using numerals and letters to abbreviate ordinals.p. spell out whole cardinal numbers one through ten and ordinals first through tenth (exceptions: citation of editions and of appellate districts). The words ―thousand..g. not 3d and 21st. use numerals (exceptions: syllabus paragraph numbers and Amendments to the United States Constitution). When numerals and spelled-out numbers would both be used for items in the same category within the same paragraph or series of paragraphs. 5. Use numerals with the word ―percent‖ and with abbreviated units of measure.SECTION NINE: USE OF NUMBERS ______________________________________________________ Generally.‖ and so on may be used to replace a string of zeros.h.‖ ―million.‖ ―hundred thousand. Numerals may be used for items that are part of a numbered series that are referred to by their numbers.000 volts $1 million or $1. do not use superscript letters: 3d and 21st.000 The Supreme Court of Ohio 93 Writing Manual . For other numbers. HOW TO USE NUMBERS paragraph two of the syllabus First Amendment to the United States Constitution Fourteenth Amendment to the United States Constitution East 105th Street 9 m.

300.27 $.06 meters 5 percent 543 automobiles 4. (Spell out numbers at the beginning of a sentence.) 12-gauge shotgun .) $1. not 40 kg of cocaine.22-caliber rifle 9 mm handgun (use numerals with abbreviations for units) NOTE: Do not use hyphens to join a numeral to an abbreviated unit of measure. NOTE: This example illustrates the exception to spelled-out numbers in text described in the last sentence above. do not use abbreviated units in measure in ordinary text: 40 kilograms of cocaine.500 in punitive damages $56. Three thousand two women registered for the event. a nine-foot pole the 11th juror two-thirds of the property five and one-half miles 12. The Supreme Court of Ohio 94 Writing Manual .05 or five cents 287.000 $7.HOW TO USE NUMBERS (CONT. 3 The farmer has 25 cows and 4 sheep. The “4” would ordinarily be spelled out.5 miles or 12½ miles fn.2 acres He saw only one man in the store. Except for caliber of firearms.3 million or $1.

5 proposition of law No. 3 NOTE: The above five examples use numerals for a numbered series. 1 stipulation No. The Supreme Court of Ohio 95 Writing Manual .HOW TO USE NUMBERS IN NUMBERED SERIES assignment of error No. 2 Count 4 of the indictment exhibit No.

The Supreme Court of Ohio 96 Writing Manual .

WHERE TO PLACE QUOTATION MARKS Bill said. causation. do not place a colon between a verb and its object or complement or between a preposition and its object. If the quote is incorporated into a question by the quoter. and (4) damages. The presence of a list does not justify using a colon in the middle of a sentence. (3) proximate cause.2.‖ ―Property. 10. In particular.01(J)(1). ―The manuscript is ready.C. do not write. Colons are properly used to introduce lists. place the question mark outside the quotation mark. breach of a duty. That is.1. means ―any property. real or personal. but only if the list is introduced by a full sentence. even if the complement or object is a list. Lists.‖ it is clear that the legislature intended ―may.‖ What did he mean by ―ready‖? Although the statute uses the word ―shall. Place quotation marks outside commas and periods but inside semicolons and colons. do not use a noun for the fifth. Placement of Quotation Marks Relative to Other Punctuation. ―The elements of a negligence claim are: duty.‖ NOTE: Observe parallelism in lists. Correct: A plaintiff in a tort case must prove (1) duty.‖ The Supreme Court of Ohio 97 Writing Manual .‖ as defined by R. HOW TO FORM A LIST Incorrect: A plaintiff in a tort case must prove (1) duty. and damages. 2901. and (4) that he has been damaged. (2) breach of that duty.SECTION TEN: PUNCTUATION ______________________________________________________ 10. (2) breach of that duty. (3) proximate cause. If the first four elements in a list are verbs.

Punctuation of Quotations.‖ He said that ―the contract was drafted by a pettifogger.‖ The Supreme Court of Ohio 98 Writing Manual .) The court gave the following examples for the use of the word ―shall‖: ―(1) * * *.‖ ―Moreover. ―shall spit on the sidewalk.‖ The statute states that ―[n]o person shall spit on the sidewalk. and the court said. change it to upper case and indicate the change with brackets. we held.‖ The statute says that ―[t]he director shall promulgate rules. HOW TO PUNCTUATE QUOTATIONS ―No person. ―The director shall promulgate rules.WHERE TO PLACE QUOTATION MARKS (CONT. use a comma or a colon and begin the quotation with an uppercase letter. ―the contract was drafted by a pettifogger.‖ the statute commands. change it to lower case and indicate the change with brackets.‖ The statute continues. If the quoted material begins with a lowercase letter. ―[T]he contract was drafted by a pettifogger.‖ 10. as in phrases such as we held that and the rule provides that.‖ He said.3. After an introductory phrase such as the statute provides.‖ he said. use no comma and begin the quotation with a lowercase letter. When a quotation is introduced with that. If the quote begins with a capital letter.

Placement of Footnote Numerals Relative to Punctuation. Note that the asterisks are separated by spaces. Indicate the omission of the end of a sentence with an ellipsis.C. The Supreme Court of Ohio 99 Writing Manual . including a semicolon. do not use an ellipsis after a period. or it may introduce the quotation. as in the first example below. do not use an ellipsis at the beginning or end of the quotation.10. the administrator or the commission may select one or more of the attorneys in the employ of the commission * * *. 4123. At the end of a quotation. When using ellipses. as in the second example. but set off the quotation by additional margins on the left and right. Ellipses. 10. Block Quotations. If what is quoted is obviously a sentence fragment. In the event the attorney general or the attorney general‘s designated assistants or special counsel are absent. The source of the quotation may follow the quotation. • • • Superscript numerals for footnotes go after punctuation. Indicate an omission of a word or words from quoted material by using an ellipsis (* * *). When a paragraph is omitted from the middle of a multiparagraph quote. HOW TO FORMAT A BLOCK QUOTATION The attorney general claimed to have a conflict of interest and declined to participate in the case in any way. R.6. Use block quotations when the text will be longer than four lines. observe the following guidelines: Do not begin a quotation with an ellipsis. 10. not a bracketed period. The statute requires the attorney general to represent the administrator and the commission.4.512(C). Use quotation marks only for quotations within the block text. including appointment of special counsel. Do not change line spacing or font. indicate the omission with a paragraph consisting of an ellipsis preceded by a quotation mark.5.

The Supreme Court of Ohio 100 Writing Manual . to justify the person‘s use of the force in question. as an element of the affirmative defense.C. 2901.06(B) provides: If a person is charged with an offense involving the use of force against another and the person. The introduction of any expert testimony under this division shall be in accordance with the Ohio Rules of Evidence.HOW TO FORMAT A BLOCK QUOTATION. raises the affirmative defense of self-defense. ----------------------------------------------------------R.CONT. the person may introduce expert testimony of the ―battered woman syndrome‖ and expert testimony that the person suffered from that syndrome as evidence to establish the requisite belief of an imminent danger of death or great bodily harm that is necessary. as a defense to the offense charged.

the footnote should be discarded. A footnote may be appropriate when the point being made is relevant but would distract the reader or interrupt the flow of an argument. 11. Footnotes are to be discouraged generally. Examples of information that may belong in a footnote: • • • • • • • Excerpts of testimony. the writer should consider whether the information being imparted is relevant and helpful.g. If not. ―The term ‗jail-time credit‘ is used as shorthand for custody credit‖). But footnotes should always be used sparingly. Contractual clauses. Legislative history. Footnotes can be helpful in certain contexts. Citations in Footnotes. for example). Procedural details (a party was dismissed. Explanatory notes (e. Do not use footnotes for legal analysis.2. Surveys. The Supreme Court of Ohio 101 Writing Manual . Do not follow the practice of relegating all citations to footnotes.. Before adding a footnote. Citations of authority belong in the body of an opinion. it may be relegated to a footnote.SECTION ELEVEN: FOOTNOTES ______________________________________________________ 11.1. If it is nonsubstantive. Use of Footnotes. it belongs in the body of the opinion. Statutory text. Footnotes are best reserved for sidelights or peripheral material. The use of too many footnotes tests the reader‘s patience and lessens the probability that any will be read. If the point being made is substantive. They are intrusive and often unnecessary.

The Supreme Court of Ohio 102 Writing Manual .

Id. When text to be italicized includes words that are already italic (typically a case name). but all three choices must be indicated by the use of ―Emphasis sic. ―The statute will always be tolled under these circumstances. Use italics for signal words. with case name in reverse italics. This so-called reverse italics applies when emphasis is added to quotations and to italicized headings and headnotes.‖ or ―Emphasis deleted.6. 12.2. Do not italicize foreign words and phrases. HOW TO USE REVERSE ITALICS The court stated. or deleted. regardless of the saving clause. unless the rule in Storer applies. but sparingly. Use of Italics. It will rarely be helpful to italicize even so much as a third of a quotation for emphasis. Reverse Italics. Emphasis is often best achieved through word choice and sentence structure.‖ (Emphasis added.SECTION TWELVE: ITALICS ________________________________________________________________________ 12.‖ ―Emphasis added. Overuse of italics can dilute the desired emphasis. In quoted material.‖ as explained in ―6..‖ in the Manual of Citations above. Emphasis Deleted. italics may be retained. and case histories in citations. Emphasis Added. Emphasis Sic. change them to roman font to preserve the contrast. Application of the Storer doctrine NOTE: Example of a heading in italics with case name in reverse italics. Never italicize an entire quotation for emphasis. The Supreme Court of Ohio 103 Writing Manual .1. added. Use italics for emphasis.) NOTE: Example of quoted phrase italicized for emphasis. case captions.

The Supreme Court of Ohio 104 Writing Manual .

Identification.g. NASDAQ. Nor are they always all capitals. DVDs. AND PARENTHETICAL REFERENCES ______________________________________________________ 13.. blog. NAVSAT.. Feb. An abbreviation is formed from the initial letter of each component word.4. e. e. Use and Overuse.L. Unfortunately. e.g. NASCAR. A printed page littered with clumps of capital letters will irritate and discourage readers. Common sense is the best guide.. CLE. appellant filed an application with the Public Utilities Commission of Ohio (―PUCO‖) to increase its rates. laser. NBC. Jones & Brown. e. AIDS.g. ABBREVIATIONS. The plural of an acronym or other abbreviation is typically formed by adding a lowercase ―s‖ without an apostrophe. use the full name with a parenthetical containing the acronym or abbreviation. The author may decide to abbreviate the name of any litigant or other entity.3.. such as Dr. Definition.1. e. are not susceptible of overuse and are not the subject of this section. in quotes. OSHA.g. Plurals. At the same time. overuse can be counterproductive. FANNIE MAE. Example: Smith. 13. and Blvd. IRS. SUVs. 13. (―SJ&B‖) sought an injunction in the trial court.C. Acronyms are not always formed from just the first letter of each component part. L.SECTION THIRTEEN: ACRONYMS. A writer should always identify acronyms and abbreviations before using them. The Supreme Court of Ohio 105 Writing Manual . MADD. Example: In July 2007.. An abbreviation need not be recognizable or widely used. PETA.2. At the first reference. Eurail. An acronym is distinguished from other abbreviations by the fact that an acronym can be pronounced. PACs. even when they are familiar to readers.g. Acronyms and abbreviations are useful tools for avoiding tedious repetition of the same phrase or name. overuse is not easily defined.... 13. NOTE: Common abbreviations formed by shortening a single word. MP3s.

Example: Doe seeks a writ of mandamus against the Board of Commissioners of Blank County. The Supreme Court of Ohio 106 Writing Manual . When the shortened form is chosen.5. The author may choose a descriptive word to use as a continuing reference for one or more persons or entities. and John Doe. Blank County Clerk of Courts.13. Parenthetical References. Blank County Treasurer (―the appellants‖). later references should always use that form.

4 Miscellaneous Caption Matters. or here.SECTION FOURTEEN: THE CASE CAPTION ________________________________________________________________________ 14. a government agency. Consider a pleading that is captioned as follows: Mary Stern and Joseph Lynch. or an original action in this court. The following rules apply to formal captions: • • • The formal caption line appears in large and small capital letters. To determine the correct formal caption for a case. go to the original complaint. XYZ Corporation and Harvey Kent and ABC Law Firm.1. References to juveniles‖ under ―14.‖ is italicized. or to a later amended complaint if it substitutes a party. whether filed in the trial court. Thus. Defendants. The Formal Case Caption. a petition for a writ in the court of appeals. The ―v.‖ below. whether it is a complaint in the trial court. Plaintiffs. The formal case caption is taken from the original pleading in a case. the name of a party who has long since dropped out of the litigation may well appear in the caption. v. The Supreme Court of Ohio 107 Writing Manual . Names of juveniles are to be treated in accordance with ―E. the court of appeals. First names are omitted. in bold type. and follow the order of names as they are listed on that pleading.

If Stern and Lynch are appellees. APPELLANT. v. If Kent is the sole appellant: STERN ET AL. for all of the examples in ―14.. ET AL.. v. If Mary Stern is the sole appellant: STERN. APPELLANT. APPELLEES. v. v. APPELLANT.” In the formal case caption.‖ In the cite-as line.. XYZ CORPORATION ET AL.‖ even if that party has long ago disappeared from the litigation and has filed nothing in this court. XYZ CORPORATION ET AL.. XYZ CORPORATION. APPELLEES. APPELLANT. The “Cite-As Line. If Lynch is the sole appellant: STERN.. ABC LAW FIRM. APPELLANTS. and XYZ is the sole appellant: STERN ET AL. APPELLEES. XYZ CORPORATION ET AL.. ET AL. the cite-as line would read: The Supreme Court of Ohio 108 Writing Manual . XYZ CORPORATION ET AL.‖ above. 14. APPELLEES. KENT. XYZ CORPORATION ET AL. the first defendant is the only name to appear after the ―v. the first defendant listed in the original pleading is always the first to appear after the ―v.. The Formal Case Caption. APPELLANT. APPELLEES.. the formal caption would read: STERN ET AL. Thus. APPELLEES. v. If ABC Law Firm is the sole appellant: STERN ET AL. LYNCH....1.2. v.HOW TO DO FORMAL CAPTIONS FOR AN APPEAL If Mary Stern and Joseph Lynch in the above pleading are the appellants in this court and all defendants are appellees.

To be an appellee. ET AL. APPELLEES AND CROSS-APPELLANTS. but not in the formal case caption. v. HOW TO DO A FORMAL CAPTION WHEN THERE IS A CROSSAPPEAL STERN.. XYZ Corp. Appellees are accounted for in the formal case caption even if they do not participate on appeal. The Supreme Court of Ohio 109 Writing Manual . in both the formal caption and the cite-as line. Miscellaneous Caption Matters.] The entire cite-as line appears in boldface. In the Matter of… 14. B. 14. a party must have had at least part of the judgment below entered in his or her favor and must stand to lose it on appeal. Always change In the Matter of to In re. Words are abbreviated in the cite-as line.. except add the parties‘ cross-appeal status to the formal citation line.4. XYZ CORPORATION ET AL. APPELLANT AND CROSS-APPELLEE. 2011-Ohio-___. Cross-appeals When a party has cross-appealed. A typical example is the workers‘ compensation claimant who lets the Industrial Commission do all the work of defending its order in the claimant‘s favor. A winner below who is not made a party to an appeal by service is not a party and not an appellee.3. follow the same rules above.. with the caption in italics. ___ Ohio St. Appellees An appellee is a party against whom an appeal is taken.3d ___.HOW TO FORM THE CITE-AS LINE [Cite as Stern v. A.

procedendo. v. RICE. 2011-Ohio-___. NOTE: In actions involving the extraordinary writs (mandamus. RESPONDENTS. will contain only the first case caption: [Cite as State v. STERN.. 2010-0803. however.] The Supreme Court of Ohio 110 Writing Manual .C. The formal caption should begin with the phrase ―The State ex rel. APPELLEE. HOW TO DO A FORMAL CAPTION FOR ORIGINAL ACTIONS THE STATE EX REL. INDUSTRIAL COMMISSION OF OHIO ET AL. APPELLEE. HAYES. ___ Ohio St. APPELLANT. starting with the case with the lowest (oldest) Supreme Court docket number. THE STATE OF OHIO. prohibition. State v. APPELLEE. NOT THE STATE EX REL.‖ D. THE STATE OF OHIO. HOW TO DO A FORMAL CAPTION FOR CONSOLIDATED CASES For instance. Hart Case No. Consolidated cases When two or more cases have been consolidated for a single decision.3d ___. the party bringing the action is the relator and the party against whom the action is brought is the respondent. HART. v. The cite-as line. APPELLANT. STERN v. RELATOR. Rice Case No. v. INDUSTRIAL COMMISSION OF OHIO ET AL. APPELLANT. and quo warranto). State v. Original actions When the case is an action originating in this court. Hayes. the formal citation line will not include the parties‘ status. Hayes The formal caption lines would read: THE STATE OF OHIO. each case has its own separate formal caption line. v. State v. say that the following three cases have been consolidated for decision: Case No. 2010-1201. 2011-0140.

that person should also be identified by initials or by familial relationship. To the extent that reference to another person is likely to reveal the identity of the juvenile. References to juveniles In any case in which a juvenile is a party. given name and last initial. or pseudonym. or pseudonym.E. In all cases. given name and last initial. Any published opinions issued by the court shall similarly refer to the juvenile by initials. or pseudonym. given name and last initial. judges shall not allow publication of a minor‘s identity. the caption of the case shall refer to the child by initials. In any case involving a minor victim of child abuse or a minor victim of a sex offense. any published opinions of the court shall refer to the minor victim by initials. The Supreme Court of Ohio 111 Writing Manual .

The Supreme Court of Ohio 112 Writing Manual .

1.g. in addition to text. Numbered headings without descriptive text convey no meaning. if the content of an opinion has more than two levels of division. e. Do not use numbers alone. should be considered. Headings allow the reader to more easily understand the flow of an opinion and to identify portions of interest.g. provide examples of effective headings. Accordingly.. Headings are not followed by periods. Structure of a Judicial Opinion. the use of numbers and letters. Whether numbers and letters should be used in addition to a descriptive heading (e.SECTION FIFTEEN: HEADINGS ________________________________________________________________________ 15. provide examples of the effective use of headings. Use of Headings. Laches) will depend on the complexity of the opinion. Generally. Form of Headings. choose headings that clearly identify the content of the applicable material. IV. Use headings when they will enhance the reader‘s understanding of the opinion or facilitate the reader‘s ability to focus on a single issue or to cite a specific part of the opinion. Structure of a Judicial Opinion. The sample opinions included in Part III.2. The reader of a short or single-issue opinion might find headings more intrusive than helpful. 15. The Spousal Privilege. Not all opinions will necessarily benefit from the use of headings. III. An exception exists for headings composed of combinations of a numeral and a word or phrase that are on the same line. The specimen opinions included in Part III of the Writing Manual. The Supreme Court of Ohio 113 Writing Manual . in which a period will follow the numeral only.. It is the opinion author‘s prerogative whether to divide an opinion into subparts with headings.

The Supreme Court of Ohio 114 Writing Manual .

For example. The primary sources for the definitions in the entries are Merriam-Webster’s Collegiate Dictionary (11th Ed. to educe the defendant‘s complete account of what occurred. A Dictionary of Modern Legal Usage (2d Ed. however. The Elements of Legal Style (2d Ed..‖ Used as a verb. ―The mediator sought to effect a settlement. Afterward is preferred. the list identifies concrete rules for legal usage. above-mentioned.2002). The primary sources for rules of usage are Garner. COMMONLY MISUSED WORDS AND PHRASES 1. accordance.‖ ―The wound affected his ability to walk.1995). but legal writing experts appear to have reached a consensus on a preferred use. ―Our holding is in accord with the holdings of other courts in Ohio. the case or the court being referred to. ‖ Deduce means to infer.‖ 3. effect means to achieve or bring about.‖ In accordance means in conformity or compliance with.2000). In some instances. on direct examination. Accord. where a particular use is debatable.‖ 5. Affect. ―The indictment was adequate for the defendant to deduce information necessary for his defense. For example. ―Her attempts to affect the legislative process were unsuccessful. For example. effect. educe. avoid these designations and use more specific references. afterwards. ―It was proper for trial counsel. Adduce means to offer as proof. In accord means in agreement. For example. above-quoted. ―The state failed to adduce evidence of prior calculation and design. and Strunk & White. Afterward. In general.‖ Effect as a noun means result.SECTION SIXTEEN: COMMONLY MISUSED WORDS AND PHRASES ______________________________________________________ The following list contains words and phrases that legal writers often confuse and misuse. In general. Adduce. ―The legislation had the desired effect. For example. The Supreme Court of Ohio 115 Writing Manual . deduce.‖ Educe means to draw out. Affect as a verb means to influence or act on. e. Above.g.‖ 4. Garner. 2. ―The officer conducted her search in accordance with constitutional standards. For example. For example. The Elements of Style (4th Ed. For example. above-cited. The Reporter‘s Office generally will follow these preferred usages.2003) and Webster’s New International Dictionary (1986). etc. the entry indicates that a particular use is preferred.

10. For example. alternate means every second one or substitute. For example. When used as an adjective. Allege means to assert something as true without having yet proved its truth. The plural of amicus curiae is amici curiae. usually one of two choices. For example.‖ 8. For example. The Supreme Court of Ohio 116 Writing Manual . reputed: ―The purported author. Appendices. Around. we decline to address them on appeal. Alternate.‖ Alternative can also mean affording a choice. because. not amici briefs.‖ To avoid confusion. Because is the preferred choice to indicate causation. assumed to be such.) 6. alleged means accused or claimed to be as asserted.‖ 12. since is also acceptable. purported. as in ―The committee offered several alternative plans. she identified her boss as the alleged perpetrator of the fraud. Use cited with approval. ―This court has cited with approval a three-pronged test concerning warrantless entry in emergency situations. she argued that counsel should have presented the alternative theory that she shot the victim in self-defense. used as an adverb. Amicus curiae. For example. Use the more formal about or approximately. For example. since. Friend of the court. alternate means a substitute or something that occurs or succeeds by turns. alternative. 9.‖ Purported means supposed. ―Because [or Since] the trial court did not consider these issues. ―The defense presented alternate jury instructions.‖ 7. Alleged. ostensible. Approvingly cited. As. supposed. When used as a noun. Amicus brief.‖ Ostensible means apparent. When used as an adjective. The plural of amicus brief is amicus briefs. alternative means mutually exclusive. as to the latter meaning. but suggests that appearance may not reflect reality.COMMONLY MISUSED WORDS AND PHRASES (CONT. ―In her complaint. 13. Either spelling is acceptable as the plural of appendix. 11. the plaintiff alleged that her employer owed her money. ―Although the defendant claimed that she did not intend to shoot the victim. appendixes. do not use as to mean because.‖ An alternative is a choice. ―The attorney‘s ostensible reason for attending the conference was legal education.

Use as such to refer to an object or idea just expressed. was a natural for the role of foreman.‖ Among indicates a collective or undefined relationship. Between indicates a one-to-one relationship. For example. ―The will ensures her daughter‘s comfort for life. Use attorney fees. Clearly. among. Between. persuade. ―The juror was a military officer and. Assure means to convince another of something. ―He insured his home for more than it‘s worth. the phrase comprised of is always wrong. cite to.‖ Citation is a noun and is preferred over cite. ―Counsel persuaded the jury to return a defense verdict. For example. For example.‖ 21. Avoid using clearly and obviously as mere intensives. ―Defense counsel convinced the jury that his client was innocent. even if there are more than two objects at issue. Assure. As such.‖ Ensure means to make sure or certain. not attorney’s fees or attorneys fees.‖ 19.) 14. in most legal contexts. Compose. means to refer to or offer as an example or authority. insure. Convince indicates a mental state.‖ The Supreme Court of Ohio 117 Writing Manual . For example. 17. as such. For example. Cite.‖ Comprise means to include or contain. 15. Attorney fees.‖ Insure means to provide insurance. obviously. where appropriate. Compose means to form or produce.‖ 18. ensure. ―The bonds between the three defendants supported a united front for the jury. Use cite.COMMONLY MISUSED WORDS AND PHRASES (CONT.‖ Persuade indicates a resulting action. ―Six Ohio counties compose the Second District Court of Appeals. For example. For example. ―Defendant cites Miranda as support for his arguments. therefore. For example. comprise. ―The consensus among the three defendants was that they had been framed. For example. For example. Cite is a verb and. citation.‖ 16.‖ Do not use as such merely to connect sentences or phrases or as a substitute for therefore. ―The Second District Court of Appeals comprises [or is composed of] six counties. ―Appellant offers a single citation in support of his theory. not cite to. For example. Convince. ―The defendant assured the victim that the basement was safe. For example. 20.

―The trial court denied plaintiff‘s request to submit historical data concerning other jury awards.‖ 24. Identical with. Impact. For example. credible evidence supports the trial court‘s findings. Historic means famous or important in history. sway.‖ Rather than using impact as a verb.‖ Historical means of or relating to history. ―This appeal presents the issue whether the trial court abused its discretion by overruling plaintiff‘s objection. A court makes findings on questions of fact and holdings (or conclusions) on questions of law. Do not use it to refer to a difficult choice. Hopefully means in a hopeful manner. ―We can infer from the applicant‘s failure to disclose three prior terminations that she intended to deceive the review board. Issue of whether.COMMONLY MISUSED WORDS AND PHRASES (CONT.‖ Infer means to arrive at a conclusion from facts or premises. Historic. as appropriate.‖ 29. Use impact only as a noun. 30. Finding. or influence. Imply. 27. For example. infer. use affect or. For example.) 22. Both are correct. historical.‖ 23. A Hobson’s choice is an apparently free choice that offers no real alternative. Judges and courts make and issue decisions and judgments. Irregardless. Do not use it to mean it is hoped. touch. Imply means to indicate or express indirectly. For example. For example. we hold that appellant was entitled to judgment as a matter of law. ―The opening of the new Supreme Court building was a historic occasion. For example. Use issue whether. ―This language implies that a court may dismiss the claim if the conditions are met. ―The defendants‘ actions affected the community.‖ The Supreme Court of Ohio 118 Writing Manual . opinion. readers infer. For example. judgment. holding. Use irrespective or regardless.‖ Speakers and writers imply. 28. identical to. 31. 26. For example. For example. ―Because competent.‖ 25. Hopefully. ―The impact of the defendants‘ actions was widespread throughout the community. ―The trial court‘s opinion fails to explain its decision granting summary judgment. Decision. Hobson’s choice. They write opinions to justify decisions and judgments.

‖ 40. mention. Method means a process for attaining something. 36.‖ May means is permitted to. the General Assembly proscribed this conduct altogether. means to supply with references. it’s. Practical means useful or nontheoretical. 33. Rebut. In legal contexts. practicable. Must. Its is the possessive form of it. argue. ―The trial court imposed practical procedures for concluding discovery. ―The company challenged the agency‘s assertion that the pollution-control guidelines were practicable. used as a verb. 37. refer typically means to direct attention to. For example. For example. or refer to.‖ 39.‖ 35.‖ Practicable means feasible.) 32. 34.‖ Proscribe means to forbid.‖ ―The plaintiff shall serve the defendant within 30 days. For example. For example. Do not use reference to mean cite. Posit means to state as a premise. ―The defendant rebutted the witness‘s testimony by presenting his own witness. the General Assembly prescribed a strict method for determining whether the actions were lawful. For example. Must and shall mean is required to.‖ Methodology means the study of methods. ―Through this statute. or state. to postulate. ―All parties must follow the Rules of Civil Procedure. Pleaded and pled may be used interchangeably.‖ Posit is not synonymous with present.‖ 38. may. Posit. refute. Refer. The Supreme Court of Ohio 119 Writing Manual . For example. Prescribe. reference. For example. ―The plaintiff may serve the defendant personally. Practical. Rebut means to contradict. ―Through this statute. proscribe. For example. methodology. Method. Prescribe means to dictate. pled. For example. ―A court speaks only through its journal. shall. Pleaded.‖ Refute means to prove wrong.COMMONLY MISUSED WORDS AND PHRASES (CONT. ―He referred to his relationship with the codefendant only in passing.‖ It’s is the contraction of it is or it has. which.‖ Refer is not interchangeable with reference. Its. For example. ―The videotape image of the defendant refuted his claim that he had never been there. ―The prosecutor‘s theory of the case posited a common motive for the crimes. For example. For example. ―The Supreme Court has clarified the method we must use to assign responsibility in multiple-employer situations.

savings clause. ―The court found that defendant‘s tortuous explanation of his whereabouts lacked credibility.‖ The issuance of a writ of mandamus to an agency does not constitute a remand to the agency. Toward.) 41. Said. that. ―The business. Scenario. survivorship. The Supreme Court of Ohio 120 Writing Manual . 42. 50.e. Use saving clause.‖ Tortuous means marked by repeated twists or turns. towards. use on instead. Respective. Generally. should be punished. 46. For example. Saving clause. i. person. ―We remand this case to the trial court for a new hearing. 49. i. remand back. For example.COMMONLY MISUSED WORDS AND PHRASES (CONT.e. 44. tortuous.. or this.‖ Torturous means causing torture. Use that to introduce an adjective clause containing essential information about the preceding noun. For example. It is often an unnecessary adjective and may be deleted. Use remand alone. For example. An estate pursues a survival action to recover for the decedent‘s pain and suffering before death and for other associated losses. person. ―A business that violates environmental laws should be punished. ―The parties argued their positions. such as the.‖ Use which to introduce clauses containing supplemental information. Scenario refers to imagined events. Toward is preferred. not savings clause. Use more specific references. 47. ―Plaintiffs complained about defendants‘ tortious conduct. which violated environmental laws. That.‖ not ―their respective positions. Upon. ―Both federal acts contain broad saving clauses that preserve rights and remedies existing outside the securities arena. For example. For example.‖ 48. It is not synonymous with situation. Tortious means involving a tort.‖ 45. which. For example. Avoid referring to an object. Survivorship is a right that arises by virtue of a person having survived another person with a joint interest in property. Remand. Survival action. the said. or idea as the said object. clauses that are set off by commas and could be eliminated without changing the meaning of the sentence.‖ 43. Tortious.. Respective means separate or particular. a clause that cannot be eliminated without changing the meaning of the sentence. torturous. or idea.

‖ The Supreme Court of Ohio 121 Writing Manual . oral. For example. 53. For example. Verbal.‖ 52. Whether. ―The judge had decided in advance to disbelieve the defendant. whether or not. written or spoken: ―The student‘s essay amply demonstrated her verbal skills. Verbal refers broadly to words. Verbiage means an excess of words with little value.‖ Oral is narrower and means spoken.) 51.‖ An exception applies when the whether clause is an adverb.COMMONLY MISUSED WORDS AND PHRASES (CONT. ―The trial court had discretion to determine whether the defendant was telling the truth. Use whether alone. Verbiage. ―The parties had an oral agreement to settle the case. For example. whether or not the defendant was telling the truth.

The Supreme Court of Ohio 122 Writing Manual .

PART III. STRUCTURE OF A JUDICIAL OPINION A Guide for the Writer The Supreme Court of Ohio 123 Writing Manual .

The Supreme Court of Ohio 124 Writing Manual .

All three cases are arranged as they would appear in the Ohio Official Reports. except that marginal notes have been added to identify outline elements and explain certain points. arranged in the traditional sequence (Section Eighteen). whose structure follows the outline (Section Nineteen). The Supreme Court of Ohio 125 Writing Manual . It then presents three examples of fictitious Supreme Court opinions. First. The guide is meant to provide a basic model that can be easily followed and adapted for a variety of cases. Finally. Next. it sets forth the basic components and their subcomponents.INTRODUCTION TO STRUCTURE OF A JUDICIAL OPINION _____________________________________________________ The Structure of a Judicial Opinion is offered as a guide to organizing a straightforward judicial opinion. two civil and one criminal. Section Twenty-One considers the topic of separate opinions. it addresses the subject of authorial discretion (Section Seventeen). with examples of various dispositions. There are many ways to write a good judicial opinion. Section Twenty discusses dispositional language.

The Supreme Court of Ohio 126 Writing Manual .

Thus. and conclusion is a good starting point. However. for example. a section labeled ―II. The author‘s own outline of facts. it must be remembered that once an opinion is divided into sections. if desires.SECTION SEVENTEEN: AUTHORIAL DISCRETION ______________________________________________________ Organization of an opinion is solely a matter for the author. analysis. The factors listed in the sample guide may be useful. each section must have at least two subparts. with further divisions added. as the opinion is fleshed out. Defamation‖ cannot have a subsection ―A. but they are not mandatory.‖ The Supreme Court of Ohio 127 Writing Manual . Communication to Third Party‖ without a section ―B.

The Supreme Court of Ohio 128 Writing Manual .

Articulates rationale and. rules. statutes. 12(B)(6) dismissal? On judgment after full trial? b. Identifies rationale for trial court‘s decision. relevant incidents before any court or agency involvement. appellee).. Establishes procedural posture: a. A. B. The Supreme Court of Ohio 129 Writing Manual . Introduction • Identifies the main issue of the case. • States the court‘s conclusion.SECTION EIGHTEEN: OUTLINE OF A JUDICIAL OPINION _____________________________________________________ The following is offered as guide to arranging the elements of a traditional judicial opinion in the Supreme Court. Applies legal principles to facts. In criminal case. case law. Explains parties‘ arguments. States who appealed to court of appeals and why. Distinguishes precedent. if warranted. 2. i. OUTLINE OF A JUDICIAL OPINION I. In civil case. Settles conflicting cases. Identifies parties and their status (appellant.) 1. Statement of Facts 1. 3. d. 4.R. Articulates in precise terms the question presented by the appeal. when appropriate: a. was case decided on plea of guilty or no contest? On granting of motion to suppress? On judgment after full trial? 2. 2. b. If reversing.e. c. Identifies sources of legal principles (constitutions. • Summarizes the facts. Identifies which standard of review applies and why. Describes relevant and material events that prompted filing of civil lawsuit or criminal charges. etc. C. was case decided on summary judgment? On Civ. II. Procedural History 1. B. identifies error and explains flaw. Describes how the court of appeals decided the appeal. Legal Analysis A.

Explains what. specifies where. If remand is ordered. 2. Conclusion A. Summarizes basis of decision B.) III. if anything.OUTLINE OF A JUDICIAL OPINION (CONT. The Supreme Court of Ohio 130 Writing Manual . happens next. States disposition 1.

1.SECTION NINETEEN: EXAMPLES OF OPINIONS CONSTRUCTED ACCORDING TO THE OUTLINE ______________________________________________________ 19. A parenthetical explanatory note may be added at the end of a syllabus paragraph that cites an affected case or statute. The old rule that the syllabus. B. Overview. and the authorities cited in them. (State ex rel. text from the body of the case. which appear only on Lexis. being interpreted. and only the syllabus.2d 448. Comm. Headnotes are for research purposes only. The following section consists of three Supreme Court opinions. ―Real property‖). two civil and one criminal. the purpose of the syllabus is to summarize the legal principle set forth in the opinion. Syllabus The role of the syllabus in Ohio has changed. including footnotes. Notes in the right margin point out where elements from the outline appear. They provide key words and phrases describing the general subject matter of the case (e. Rule 1 of the Rules for the Reporting of Opinions reads: ―(B)(1) The law stated in a Supreme Court opinion is contained within its syllabus (if one is provided). and do not constitute part of the opinion. not by the court. ―Taxation‖). with a word or phrase that explains how that case or statute is affected by the principle in the syllabus. The entire text of the opinion contains the law. and the holding. may be cited as authority. Timken Roller Bearing Co. which appear on Westlaw and in the West regional reporters but not in the Ohio Official Reports. They are written by the Supreme Court Reporter‘s Office. with certain additional features.) The Supreme Court of Ohio 131 Writing Manual .C. They are to be distinguished from the more extensive headnotes written by West. Example: R. Indus. (1939). the statute. if any. All three opinions. and notes in the left margin offer explanations regarding the format of the opinion. The opinions include notes in both margins. A. 4123. and its text.2. including footnotes. modified. Components of an Opinion. 136 Ohio St.g. v. contains the law of the case has been discarded.52 is not applicable to occupational-disease claims that require total disability or death to be compensable.E. Headnotes The headnotes are the italicized phrases under the caption. They are presented as they would appear in the Ohio Official Reports.. the subtopics (say. and from those written by Lexis. 24 N. are completely invented. The syllabus controls over text only when the text conflicts with the syllabus. and all follow the outline contained in Section Eighteen.‖ Currently. 148. 19.

They are added by the Reporter‘s Office before the slip opinion is released. this line uses county only. No. This line is referred to as the ―cite-as line. Identifies parties and their status. to buy a car. The Supreme Court of Ohio 132 Writing Manual . not by the court. ____________________ Per Curiam.Example 1 . but often helpful. States the court‘s conclusion. plaintiff-appellant. 2009—Decided October 10. As Doe was crossing the lot.e. he slipped on a snowcovered icy spot and fell. that the natural accumulation of snow and ice on his premises was substantially more dangerous to his business invitees than they could reasonably have expected from their knowledge of conditions prevailing generally in the area. APPELLEE. especially in a lengthy case with multiple issues. Facts and Procedural History {¶ 2} On December 12.. either ―Doe‖ or ―appellant‖—and stick with it. the owner is not liable for any injury resulting from snow and ice. The court reasoned that when the owner or occupier of business premises is not shown to have had notice. 2002. i. Establishes procedural posture—case decided on summary judgment. 2009Ohio-0000.‖ [Cite as Doe v. John Doe. A per curiam opinion generally does not have a syllabus. {¶ 1} The issue presented in this appeal is whether an owner of property is liable to a business invitee who is injured on the property when he slips on a patch of ice covered by snow.) APPEAL from the Court of Appeals for No-Name County. V. XYZ Auto Sales. 2008-0000—Submitted July 1. XYZ AUTO SALES. 00000. The trial court granted XYZ‘s motion for summary judgment. Describes relevant events that prompted filing of lawsuit. 2009. visited the business premises of defendant-appellee. actual or implied. We conclude that the owner is not liable when snow-covered ice prevails generally in the area. Although the car lot had been plowed the day before. Unlike in citations. Note the use of paragraph numbers. an overnight blizzard caused a fresh accumulation of ice and snow. alleging negligent failure to maintain the lot in a reasonably safe condition. {¶ 3} Doe sued XYZ. These italicized headnotes are written by the Supreme Court Reporter‘s Office.] Negligence – Premises liability – Duty to business invitee – Ice and snow – No duty owed to business invitee for injury from fall on ice and snow when conditions on premises are substantially similar to those prevailing generally in area. Choose one moniker for a party—here. not district. XYZ Auto Sales. APPELLANT. (No. relevant incidents before any court or agency involvement. Identifies the main issue and summarizes the facts. Single Issue DOE. Use of headings is discretionary. Identifies rationale for trial court‘s decision. because the owner may assume that the business invitee will apprehend the danger and act to ensure his own safety.Civil Case. breaking his wrist.3d 444. 000 Ohio St. 2008-Ohio-0000.

We decline to recognize such an exception under the facts of this case. because the ice that caused his fall was concealed under a covering of snow and the danger was therefore not obvious. Sets forth legal principles and identifies sources of legal principles. {¶ 8} In Ohio. 000 Ohio St.{¶ 4} Doe appealed.3d 444. ¶ 9. 000 Ohio St.2d 222 (2001). Articulates in precise terms the question presented by the appeal. an owner or occupier owes no duty to keep the business premises free from natural accumulations of snow and ice. 56. Englewood. ABC Corp. 000 N. XYZ had no right to assume that visitors to its premises would recognize the danger and act to ensure their own safety. Lacey v.E. Seeley v. Doe has made no such showing. 447.. Garcia v. Describes how the court of appeals decided the appeal. 000 Ohio St. Thus.E. 556. {¶ 9} Doe claims that the general rule does not apply here. Doe presented no evidence that this danger substantially exceeded the danger posed by conditions generally prevailing in the area.‖ Spears at 445.‖ Spears v.3d 333. In fact.2d 777.2d 222 (1989). 000 N. in which a business owner may be liable for an injury to a business invitee caused by a natural accumulation of snow and ice on the premises. holding that even if the ice underneath the snow was hidden. he claimed. Question Presented {¶ 6} We are asked to define the circumstances. governed by the standard set forth in Civ. Identifies which standard of review applies and why.3d 888.3d 555. alleging that the trial court had failed to consider that XYZ had superior knowledge of a hidden danger because the ice that caused his fall was under the snow and not observable by Doe.2d 444 (2000). {¶ 5} The court of appeals affirmed.E. Acme Co. if any. Applies legal principles to facts. 335. The Supreme Court of Ohio 133 Writing Manual . we review this appeal de novo. 000 Ohio St.E. This court has held that the dangers posed by snow and ice are obvious and that ―the owner or occupier has a right to assume that his visitors will appreciate the risk and take action to protect themselves accordingly. Analysis {¶ 7} Because this matter was decided by summary judgment. Explains parties‘ arguments. he admitted that icy patches concealed by snow were common that day because the melting snow had refrozen during the snowfall the previous night. 000 N. 2004-Ohio0000. 000 N.. States who appealed and why. Gallagher. A plaintiff seeking damages from a slip and fall on snow or ice has the burden of showing that the conditions that caused the injury were ―substantially more dangerous than those prevailing generally.R.

C. and JOHNSON.Conclusion {¶ 10} Because XYZ has demonstrated that no genuine issue of fact exists as to an essential element of Doe‘s claim. pro se. Abraham Lincoln. CLINTON. for appellee. XYZ is entitled to judgment as a matter of law. ____________________ The Supreme Court of Ohio 134 Writing Manual . {¶ 11} Accordingly. the judgment of the court of appeals is affirmed.J. JJ. Sets forth the disposition.. FORD. Articulates rationale. The plaintiff‘s attorneys are always listed first. BUSH. Judgment affirmed. CARTER. concur. and NIXON. ____________________ John Doe. Only those attorneys whose names appear on the merit briefs or who argued at oral argument are listed. The trial court therefore did not err in entering summary judgment for XYZ.. regardless of who is the appellant in this court. REAGAN.

This case presents two issues: (1) Has a defendant who strikes another. Introduction Division of the opinion into numbered parts is discretionary. APPELLEE AND CROSS-APPELLANT. 2009—Decided June 1.Example 2 . breaking his nose. No. The Supreme Court of Ohio 135 Writing Manual .C.C. 2903. but it can be helpful. {¶ 1} John Doe was convicted by a jury of one count of felonious assault under R. 2903.11(A)(1)? and (2) Can a defendant be convicted of the R. APPELLANT AND CROSS-APPELLEE. 2009.C.C. Do not use numbers without descriptive headings. 2009-0000—Submitted March 15. page 127.11(D)(1)(a) ―peace officer‖ specification when the victim was off duty at the time of the assault? We conclude that a broken nose qualifies as serious physical harm and that a defendant who assaults a police officer may be convicted of the ―peace officer‖ specification even if the officer was off duty and out of uniform at the time of the assault. Summarizes the facts and states the court‘s conclusion.] Criminal law – Felonious assault – Definition of “serious physical harm” – R. 2903.11(A)(1). 2903.11(D)(1)(a) specification that his victim was a police officer.3d 222. ____________________ SYLLABUS OF THE COURT A defendant who assaults a police officer may be convicted of the ―peace officer‖ specification in R.C. V.) APPEAL and CROSS-APPEAL from the Court of Appeals for Hypothetical County. caused ―serious physical harm‖ within the meaning of R. (No. [Cite as State v.11(D)(1)(a) – Defendant may be convicted of specification if officer is off duty and out of uniform at time of assault.C.Criminal Case. 000 Ohio St. Two Issues THE STATE OF OHIO. I. DOE.11(D)(1)(a) even if the officer was off duty and out of uniform at the time of the assault. with the R. 2903. 2009-Ohio-0000. J.C. 2903. 2903.11(A)(1) – “Peace officer” specification in R. Doe. 2008-Ohio-0000. See note regarding role of the syllabus. ____________________ COOLIDGE. especially in lengthy cases. 0000.

{¶ 5} Doe appealed the affirmance of his conviction. which enhanced the penalty. The Incident and Its Aftermath {¶ 2} On October 19. Doe cursed Smith and stepped toward him menacingly.11(A). because Smith was not engaged in his official duties at the time of the assault. {¶ 8} R. Doe’s Appeal {¶ 6} Doe asks us to reverse the appellate court‘s ruling that the injury in this case can be termed ―serious physical harm‖ as required for a conviction under R. ruling that Smith‘s injury constituted serious physical harm. Ohio. {¶ 7} In reviewing the sufficiency of the evidence supporting an essential element of a criminal offense. an off-duty police officer hired by the school to provide security. 2903. {¶ 4} Doe appealed. But the court reversed Doe‘s conviction under the specification and remanded for resentencing. He contends that the evidence was insufficient to show that Smith‘s injury resulted in substantial suffering. 2903. i.C. Articulates in precise terms the question presented by the appeal. Establishes procedural posture—defendant convicted after jury trial. 000 Ohio St.C.II.E. any rational trier of fact could have found the element proven beyond a reasonable doubt.11(A)(1). 2903.‖ Identifies parties and their status (in a criminal case. 2005.. 000 N. the defendant is often the only one identified. Kim.11(D)(1)(a). III.3d 6. and the trial court sentenced him accordingly. ¶ 3.11(A)(1) and that the specification conviction was erroneous because Smith had been off duty. approached Doe and ordered him to desist. Identifies which standard of review applies and why.e. 2903. Doe became belligerent and caused a disturbance. Smith grasped Doe‘s arm. Describes relevant events that prompted the filing of criminal charges. {¶ 3} Doe was arrested and charged with one count of felonious assault under R. 2903. holding that Doe could not be found guilty of the peace-officer specification. a court must determine whether. Doe shook him off and punched Smith in the face. arguing that the harm Smith suffered was not ―serious‖ as required by R. A jury found him guilty. 2005-Ohio-0000. as the plaintiff is almost always the state). The court upheld the assault conviction.11(A)(1).C.C.2d 1. along with a specification of assault on a peace officer under R. felonious assault.C. states: {¶ 9} ―No person shall knowingly * * *: {¶ 10} ―(1) Cause serious physical harm to another * * *. In the parking lot after the game. Describes how the court of appeals decided the appeal. The Supreme Court of Ohio 136 Writing Manual . after viewing the evidence in the light most favorable to the prosecution. and the state cross-appealed the judgment reversing the specification conviction. breaking his nose. State v. Joe Smith. relevant incidents before any court or agency involvement. States who appealed to the court of appeals and why. defendant-appellant and crossappellee John Doe attended a high school football game in Anytown.

C. The State’s Cross-Appeal {¶ 16} In its cross-appeal.11(D)(1)(a) requires a showing that the officer was engaged in his official duties at the time of the felonious assault.2d 40 (slash in scalp requiring six stitches). courts have held that similarly painful but noncatastrophic injuries can constitute serious physical harm. that the examination and packing of his nose by the medic were so ―incredibly‖ painful that he nearly passed out. Morretti. his injury caused him considerable suffering. See Morretti at ¶ 6. {¶ 12} Officer Smith testified that although he was treated at the scene by medics and not transported to the emergency room. He took pain medication several times daily. e. Beadle at ¶ 11.g. These facts do not avail Doe. Articulates in precise terms the question presented by the crossappeal. not incapacity or need for complex treatment. 2d Dist. The Supreme Court of Ohio 137 Writing Manual . No.C. 0000. such as walking or thinking. State v.. 2007 WL 00000 (facial bruising). 888 N. the court of appeals did not err in affirming Doe‘s conviction of felonious assault. The relevant definition speaks in terms of pain. identifies sources of principles. {¶ 15} We conclude that Smith‘s broken nose constitutes serious physical harm.{¶ 11} In this case. 2901. No. and was assigned to desk duty for a week.B. 2903. Sets forth legal principles. 2007-Ohio-0000. 000. although short-lived. {¶ 14} In arguing that Smith‘s injury was not serious. Explains parties‘ arguments. {¶ 13} Viewed in the light most favorable to the state.‖ constitutes ―serious physical harm‖ under the above definition. states that pain that is ―unbearable or nearly so.01(A)(5). the state argued that Smith‘s injury was serious within the meaning of R. the state of Ohio asks us to reverse the appellate court‘s holding that the peace-officer specification set forth in R. this evidence demonstrated beyond a reasonable doubt that Smith had suffered ―serious physical harm‖ in the form of acute pain that is ―unbearable. which defines ―serious physical harm‖ as ―[a]ny physical harm that involves acute pain of such duration as to result in substantial suffering.Sub. Therefore.01(A)(5)(c). 2008Ohio-0000. and that he experienced frequent headaches for two weeks after the blow. or nearly so. the bill that enacted the current version of R.C. missed two days of work. Beadle. Doe points out that no emergency-room visit was required and no major function. 000 Ohio App. State v. IV.‖ The Legislative Service Commission Final Analysis of Am.S. that sleeping was difficult for several days because of the pain. He testified that the pain on impact was blinding. See.E. We have found no authority for the proposition that a victim who is treated outside a hospital or who retains his ability to walk and think cannot have suffered serious harm. Applies legal principles to facts. was affected. 2901. and articulates rationale.‖ In the context of assault.3d 342.

01. The court of appeals agreed with Doe.11(D)(1)(a). 2935.C. ―peace officer‖ includes a ―member of the organized police department of any municipal corporation. It did not.11(D)(1)(a). as he was not engaged in his official duties. statutes. 2903.C.3d 999. That portion of the judgment upholding Doe‘s conviction of felonious assault is affirmed. 2903. 000 N.01(B). Had the legislature intended that factor to be an element of the specification at issue. reversed the specification conviction. case law. No more is required. See R. {¶ 19} Smith is a police officer employed by the city of Anytown. 2903. neither the definition of ―peace officer‖ nor the specification itself requires that the officer be engaged in his official duties or in uniform for the specification to apply. Further articulates rationale.13(C)(3) (specification for simple assault applies if offense occurs while officer is ―in the performance of [his] official duties‖).C. Conclusion {¶ 22} Accordingly.‖ R. R. while the portion reversing his conviction under R. etc. felonious assault is a felony of the first degree.). ¶ 19 (3d Dist. State v. Applies legal principles to facts and articulates rationale.2d 999. Explains parties‘ arguments.). 2008-Ohio-0000. 2903.{¶ 17} Resolution of this question requires nothing more than a simple review of the statute. it could have included that language. Although he was off duty and out of uniform when he was attacked. and remanded for resentencing. The Supreme Court of Ohio 138 Writing Manual .11(D)(1)(a) and remanding for resentencing is reversed. Smith was not a peace officer.C. The judgment of the trial court is reinstated. Shaw. The evidence established that Smith was a police officer at the time of the assault. 2935. {¶ 20} Our conclusion is buttressed by the fact that a similar specification in another assault statute does expressly require that the officer be engaged in his official duties at the time of the assault. The specification incorporates by reference the definition of ―peace officer‖ in R. {¶ 18} Doe contends that at the time of the offense. Judgment affirmed in part and reversed in part. States disposition. and we will not add it. See pages 145-147 for examples of dispositions. V. Sets forth legal principles and identifies sources of principles (constitutions.C. explains which portion of the judgment is affirmed and which is reversed. Identifies error and explains flaw.E. The specification at issue in this case provides that if the victim of the assault is a peace officer. {¶ 21} The court of appeals erred in reversing Doe‘s conviction of the ―peace officer‖ specification under R. the judgment of the court of appeals is affirmed in part and reversed in part.C. Under that definition. 000 Ohio App.

retired.. J. for appellee and cross-appellant.. and Dolly Madison. ____________________ Grover Cleveland.EISENHOWER. Essex County Prosecuting Attorney. Ulysses S. and TAFT. Grant. for appellant and cross-appellee. C.. JJ. J. TRUMAN. HARDING. ROOSEVELT. of the Umpteenth Appellate District. and KENNEDY. sitting for HOOVER. concur. Assistant Prosecuting Attorney. ____________________ The Supreme Court of Ohio 139 Writing Manual . CALVIN COOLIDGE.J.

ROE ET AL. Within a few hours. ___________________ SYLLABUS OF THE COURT Physicians are not qualified to offer an expert opinion on the standard of care for nurses or on whether a nurse has deviated from that standard. INTRODUCTION This opinion is divided into headings and subheadings. Roe).3d 999. The Supreme Court of Ohio 140 Writing Manual . The defendant whose name appeared first in the original complaint is always listed first. Fictitious Hosp. [Cite as Doe v. 2009-0000—Submitted November 31. Jane lapsed into a persistent vegetative state. Jane Doe. Ohio. Divided by Headings DOE ET AL. FICTITIOUS HOSPITAL. from which she is not expected to emerge. an ER physician admitted her for hydration and observation. ___________________ FILLMORE.) April 31. 09-CA-0000. v. Upon examining her. {¶ 2} On the medical-history form she was handed in the emergency room. (No. Jane reported that she was on medication for depression. 000 Ohio St. due to a tragic series of errors by hospital personnel. If that first-listed defendant is not a party to the appeal in the Supreme Court. arrived at the emergency room of Fictitious Hospital in Nowhere. I... 2009. and vomiting.. J. 2002.Example 3 . 2009-Ohio-0000. the ―formal-caption line‖ names the next-listed party (here. APPELLEES. Multiple Issues.] Medical malpractice – Expert testimony – Physicians not qualified to testify on standard of care for licensed registered nurses – Expert testimony not required to establish recklessness of physician’s conduct in caring for patient – Award not excessive – “Day in the life” video of comatose patient not unduly prejudicial. Facts {¶ 1} On April 4. A. No. 2009—Decided APPEAL from the Court of Appeals for Nameless County. APPELLANTS. 2009Ohio-0000.Civil Case. age 20. complaining of a high fever. disorientation. even if that defendant is not appealing or was dismissed early on. following the guide on page 109. but the cite-as line does not.

Drs. because contrary to hospital policy. They were unable to reach him. The court of appeals affirmed.m. Roe was unavailable because he was drinking in a nearby bar. Roe left Jane in the care of nurses.. II... Richard Roe.667 in compensatory damages and $20 million in punitive damages. {¶ 4} At 4:30 p. {¶ 9} To show that the nurses attending to Jane Doe did not violate the applicable standard of care in failing to inform Dr. Nurses then called resident physician Francis Foe. Jane was asleep. This is a question of first impression in this state. Dr.{¶ 3} Once admitted. ANALYSIS A. and for reasons unknown. By 6:10 p. It later emerged that Dr. allocating 25 percent to Foe and 75 percent to Roe. a nurse checking on Jane was unable to wake her. Foe of Jane‘s antidepressant medication and in not checking on The several issues in the Analysis portion of the opinion may be separated into subheadings and subsubheadings. The hospital settled and was dismissed. alleging negligence and recklessness in the care and supervision of their daughter and seeking compensatory and punitive damages. This heading will cover the portion of the opinion in which the court considers the arguments and formulates its holdings. Helpfulness to the reader is the touchstone. Jane was evaluated by Dr. nurses failed to check on her for the next several hours. nurses tried to contact Roe. who was on duty.m. but he prescribed ibuprofen to reduce the fever. Jane had lapsed into a persistent vegetative state and will most likely never emerge. however. when she became agitated and began trying to pull out her IV tubes. Procedure {¶ 6} Appellees John and Jean Doe. Physician Testimony on Standard of Care in Nursing Profession {¶ 8} Appellants argue that the trial court erred in refusing to allow their physician-expert to testify as an expert regarding the standard of care expected of a registered nurse. The jury found for the Does and awarded them $10. The Supreme Court of Ohio 141 Writing Manual . the latter against Drs. He could not pinpoint a diagnosis. Jane‘s parents. Foe prescribed a sedative and ordered that Jane be restrained. B. he had turned off his beeper and cell phone and left the building. brought this action against appellants. {¶ 7} A jury trial commenced in July 2005.m. {¶ 5} Jane‘s vegetative state was caused by the interaction of her depression medication and the sedative administered to control her agitation. An hour later. At 10:32 p. Without examining her personally and without inquiring what medication Jane was taking. an interaction that is known to cause severe harm or even death. Roe and Foe only. Roe and Foe and several nurses.288.

W. 000 Mass. ¶ 11. 40. 000 N. the witness must be licensed in that field. Jones.2d 3333 (2006) (citing cases). appellants proffered the testimony of John Q. 2004-Ohio-0000. {¶ 14} The clear majority of states hold that physicians are not qualified to offer an expert opinion on the standard of care for nurses or on whether a nurse has deviated from that standard. 2009-Ohio-0000. practices.E. Kress v. Thus.E. Fedders.Med. and the court‘s ruling will not be overturned absent an abuse of that discretion. Physicians are not licensed in nursing. Pediatric Ctr. Lopez v. a specialist in internal medicine at Fictitious.2d 4433. We therefore look to our sister states for guidance. Brockmeier v. 2008-Ohio-0000. {¶ 10} ―The admissibility of expert testimony is a matter committed to the discretion of the trial court. The trial court refused to permit Dr. Surgeons. Horning. 000 N. who taught nurses at the hospital. ¶ 33.2d 1235 (1985). Bolt at 813.‖ In re Carmody. Neurological Assoc.. a specialist in radiology cannot testify on the standard of care for a general surgeon.Y.2d 1099 (2007)..J.. He also consulted with the nursing staff on a guide to nursing practices and protocols.her for over four hours.Rptr. {¶ 11} It is a general rule that in order to testify as an expert on the standard of care in a given school of medicine. Bristow v.2d 1311.3d 800.3d 929. Verhoff v.3d 111. nor can an orthopedist testify on the standard for a neurologist. {¶ 12} The rationale behind this licensure requirement is that different schools of medicine have varying procedures. 000 Ohio St. Judge Thyself: The Growing Trend Toward Limiting Physician Opinion Testimony. 000 Ohio St. 230.E.E. M. 000 N. 000 N.3d 677. 222. Public. Scanlon. 812. 000 N. 1114. {¶ 13} These are well-settled principles. 000 Ohio St. Public to testify on the grounds that he was unqualified to offer an expert opinion on the applicable standard of care for a registered nurse.3d 2222 (2002) (citing cases). Physician. 000 Cal.D. The Supreme Court of Ohio 142 Writing Manual . Once that licensure has been established. and it would be unfair for a practitioner of one school to judge the care and skill of a practitioner of another. 000 Ohio St.Litig. 000 N. Inc. 000 S.3d 1111. 15-16. 66-71 (1999).E. and treatments.3d 12. 000 P. To allow them to opine on the standard of care would lead to the same muddling of methodologies and principles as allowing a pediatrician to judge a sleep specialist.S. 000 N.E.2d 933. But no Ohio court has ever addressed the issue presented here: whether a physician of any stripe may testify as an expert on the standard of care applicable to a nurse. ¶ 25. the trial court has discretion to determine whether the witness is qualified to testify as an expert regarding the standard of care.. Bolt v.

Public is familiar with the methods.‖ or so exaggerated as to strongly indicate passion. 000 Ill.000 in noneconomic damages. the trial court did not abuse its discretion in granting the Does‘ motion to disqualify Dr. The Supreme Court of Ohio 143 Writing Manual . Ctr. {¶ 16} We have no doubt that Dr. at 932. so large as to ―shock the conscience. corruption.2d 555.2d 555 (1976).E. We review the trial court‘s order denying remittitur for an abuse of discretion.{¶ 15} Appellants argue that Dr. Damages This example illustrates the usefulness of subheadings.2d 444. 000 N.000. 000 S. Public as an expert on the standards of care applicable to the nursing profession. Orthopedic Ctr. 1.2d 2233 (2001). Hosp. They point to his years of experience teaching nurses at Fictitious.2d at 932. 449.667 in economic damages (past and future medical expenses and future lost wages) and the statutory limit of $1. and his extensive experience observing and working with nurses throughout his career.. as the award of compensatory damages was excessive. Relevant licensure is an indispensable requirement for qualification as an expert when a physician seeks to testify on the standard of care in a medical field.g. Younger v. that it is larger than awards made in similar cases. Nonetheless. {¶ 17} Therefore. and practices of a registered nurse. Med. syllabus. the fact remains that Dr. Penn.E.E. {¶ 20} Appellants cite similar cases in which large compensatory awards were overturned as excessive. 000 P. But it is not enough that the award is very large.3d 1000 (2008). Id. Those states that have addressed the issue have uniformly declined to deviate from this rule when a physician is offered as an expert on nursing standards. Penn v. his work on a guide on nursing practices and protocol.. procedures. Roe Corp.E.2d 928.2d 666 (Ala. See. Awards must be judged by the unique circumstances of each case. Cty. Kress. or that similar awards have been overturned. and punitive damages is further divided into subsubheadings to discuss the two separate issues on that topic. 000 N. e..288.2d 444. Hanna v. Compensatory Damages {¶ 18} Appellants claim that the trial court erred in denying their motion for remittitur.2000). We will not disturb a jury award for excessiveness unless it is grossly disproportionate to the injury suffered.667 represented $9. 000 Ohio St. 000 Wash. The physician must be a licensed practitioner in the same field. B. {¶ 19} The compensatory award of $10. Public is nevertheless qualified to testify. The analysis is divided into compensatory damages and punitive damages. or other improper motive. Public is not a licensed registered nurse.. Bristow. 000 Ohio St. 000 N. Smoot v..App. The overarching subject is damages.288.

000 Ohio St. which was the basis for the award of punitive damages in this case. Nor are we inclined to adopt such a broad rule. The Supreme Court of Ohio 144 Writing Manual . 000 N.. Appellants have not indicated any hint in the record that the award was motivated by bias. 000 Ohio St. that she will survive in her present state for as long as five decades. paragraph four of the syllabus. who at the time of her injury was studying for a degree in urban design. 000 Ore. Further evidence established that she will never recover her mental and physical faculties.2d 2133. passion. active and healthy. Salter v. we affirm. Ray. Shorter v. and the trial court‘s superior position for judging whether the award was warranted under the circumstances.E. ¶ 20.E. Lord v. we are mindful that recklessness is defined as ―the failure to observe even slight care. or other improper motive.. It is certainly true that a plaintiff in a medical-malpractice case must present expert testimony to establish both the standard of care and deviation from that standard. Roe and Foe was reckless or wanton. Expert testimony was heard on the costs of caring for Jane for her lifetime and on the income she would have made had she not suffered this catastrophic injury. {¶ 25} Appellants contend that the Does failed to provide the expert testimony necessary to prove recklessness in a medicalmalpractice context. Goff. a. See.‖ Osgood v. 000 N. the lack of record evidence of bias or other impropriety. we apply a highly deferential standard of review and will sustain the jury‘s finding if there is any credible evidence to support it. 000 N. Lively.2d 1111. 2003-Ohio-0000. Med. {¶ 24} When reviewing the sufficiency of the evidence in a jury trial.3d 333. But appellants have cited no authority that recklessness must be established by expert testimony.{¶ 21} Here we have a very young woman. Recklessness as a basis for punitive damages {¶ 23} Appellants next argue that the Does failed to prove that the conduct of Drs.1999) (elderly patient left unattended for nearly three hours fell off examining table and died from head injuries).E.3d 888. carelessness of such a degree as to show utter indifference to the consequences that may ensue. Ctr. Davis v. and that she will always require extraordinary care in a highly specialized environment. 2003-Ohio0000. 2. In some cases. medical recklessness can be so gross and so obvious that laypersons can be relied upon to judge for themselves. 450 (Me. e. 000 Ohio St.g. ¶ 14.2d 999. {¶ 22} In view of the evidence adduced. Punitive Damages All headings and subheadings are given descriptive titles. In our review.2d 777 (1990).2d 444. Fassbinder. 000 A.

000 P. we The Supreme Court of Ohio 145 Writing Manual . Foe not reckless {¶ 27} We cannot find that Dr. Section 908. (1) Dr. Foe.‖ 4 Restatement of the Law 2d. He left without telling anyone. The award of punitive damages against Dr. Roe did much more. Community Hosp.E. His conduct was negligent—perhaps even grossly negligent—but it was not ―especially egregious. we have no difficulty in finding that Dr. Against hospital policy. Diaz v. Dr. Roe‘s voluntary misconduct strayed well beyond mere negligence into utter indifference for the consequences to his patient. at Section 908(2). He left not because he was suddenly taken ill or because of an emergency. We find no evidence of such a motive or of callous indifference here. despite being primarily responsible for Jane‘s care and despite the fact that her condition was still undiagnosed. 000 N. In such cases. Comment b. He could not be located for several hours. Punitive damages are reserved for conduct that demonstrates an ―evil motive‖ or a ―reckless indifference to the rights of others. and when he was finally found. (2) Recklessness of Dr. This court will not countenance an award of punitive damages for mere gross negligence. and the award of punitive damages against him is affirmed. Having overturned the award against Dr.‖ Id. Thus. Excessiveness of punitive-damages award {¶ 29} Appellants attack the award of punitive damages as excessive. the jury may decide whether the deviation from the standard of care was negligent or reckless. Without more. {¶ 26} We now turn to the evidence against the two doctors in this case. 000 Ohio St. Had he been available when Jane became agitated.2d 555 (1997). but because he wanted to drink. Foe is reversed.3d 666 (2001) (physician told office staff to ignore patient who had collapsed in examining room. 893. Dr. Roe was reckless. Roe left the hospital while still on duty.. Roe {¶ 28} We have no difficulty in finding support for the jury‘s finding that the conduct of Dr. Foe‘s conduct in failing to inquire about Jane‘s medications was so atrocious as to constitute recklessness.111. his knowledge of her medications might have changed the outcome in this case. because ―there was not a damn thing wrong with her‖). Torts (1965). he was too intoxicated to walk. Roe acted recklessly. But Dr. b.3d 888. He took affirmative steps to ensure that he could not be reached. we would most likely call this mere negligence.

000 L. (2). should not greatly exceed the compensatory award. as it is here.Ct. 3589.E. Here. the three-to-two ratio in this case suggests excessiveness. {¶ 30} When a jury award of punitive damages is challenged. Merritt v. to be considered reasonable. Roe.Ct. 3589. Punitive damages are warranted only when the defendant‘s conduct is outrageous and is characterized by an evil motive or by a reckless indifference to the rights of others. Merritt.. Heller v. 888. 000 S.Ed.3d 111.S. And we have no difficulty concluding that his conduct was outrageous and that it indicated a reckless disregard for his patients‘ safety. the higher the ratio.2d 3333. 000 Ohio St. Excessiveness of punitivedamages award. 2008-Ohio-0000.2d 3142.S. which must be proven by clear and convincing evidence. Hence.2d 3333. ABC Co. an appellate court must conduct a de novo review. and (3) are all subsets of heading b.Ed. 000 S. Roe‘s conduct certainly resulted in serious physical injury that is most likely permanent. the more likely that the award is excessive.S. Stubbs. 000 L. 000 U. at 899.2d 777 (1997). 000 S.2d 888 (2003). (1) Degree of reprehensibility {¶ 31} The degree of reprehensibility of the defendant‘s conduct is the most important factor in determining whether a punitive award is reasonable. at 910. 000 N.Ed. 000 N. Dr. 3513. paragraph two of the syllabus.‖ Nestor v. 000 U.S. In re Estate of Winger.E. 000 L. We have previously held that ―a court reviewing an award of punitive damages for excessiveness must independently analyze (1) the reprehensibility of the conduct.confine our inquiry to the award against Dr. and (3) sanctions for comparable conduct. Headings (1). 333. Weiss. 000 S. punitive damages. (2) the ratio of the punitive damages to the actual harm inflicted. 000 U.Ct.3d 173. the jury awarded $15 million in punitive damages and just over $10 million in compensatory damages. Here. 3589. 899. but the actual harm suffered by the patient and her family was grievous in the extreme. (2) Ratio of punitive damages to the actual harm inflicted {¶ 32} Although courts have not put a limit on the ratio of punitive damages to actual harm. 349.Ct. The Supreme Court of Ohio 146 Writing Manual . at paragraph two of the syllabus. Factors to be considered when making this determination include whether physical harm was caused and whether the defendant‘s tortious conduct indicated an indifference to or a reckless disregard of the health or safety of others.Ed. 000 L.2d 3333 (1996). 000 U. Merritt. His intoxication while on duty and in charge of patients‘ lives strongly shows utter indifference to the well-being of those to whom he owed a duty of vigilance and good faith. The United States Supreme Court has held that when the compensatory award is substantial. which amounted to $15 million. 000 Ohio St.

{¶ 36} The video in question was five minutes long and showed scenes from Jane‘s current life at a brain-injury-care facility. While the ratio of punitive to compensatory damages is high.2d 555 (2001). arguing that the prejudicial effect would outweigh whatever probative value it had. Sturgess v. ―Day in the Life‖ Video {¶ 35} Finally. at 360. 000 N. We therefore affirm the court of appeals‘ judgment on this issue. {¶ 34} Having considered the three guideposts set forth by the court in Nestor. Kendall v. C. “Day in the Life” Videos: Defense Strategies.2d 888 (1996). {¶ 37} ―Day in the life‖ videos are becoming increasingly common in trials of this sort. we conclude that the video of Jane was probative of her damage claims and that the trial court did not abuse its discretion in concluding that the probative value of this The Supreme Court of Ohio 147 Writing Manual . arguing that it was irrelevant. 000 Ohio St. which would result in an enormous loss of income.R. 403. 000 Ohio St. we find that the award of punitive damages was reasonable and proportionate to the wrong committed.3d 355. 2008-Ohio-0000. the misconduct was extreme and the harm enormous. 556 (2007). resulting in an unfair trial. Acme Corp. {¶ 38} Similarly.E. and prejudicial.2d 3142. In this case.E. it is the degree of reprehensibility that weighs most heavily in judging reasonableness.E. 449. Roe‘s license to practice medicine. 000 N. we find that the punitive-damages award in this case was not excessive. 000 N. XYZ Corp. Poe. paragraph two of the syllabus.3d 173.(3) Sanctions for comparable conduct {¶ 33} This guidepost calls for comparing the punitivedamages award to the civil or criminal penalties that could be imposed for comparable misconduct.. The relevant civil ―penalty‖ in this case is the potential damages award in a lawsuit brought by an injured patient as well as the loss or suspension of Dr. Id. at 450. appellants argue that the trial court erred in allowing the jury to view a video depicting a ―day in the life‖ of Jane Doe. inflammatory. Thus. We also rejected an argument that the video in that case had no purpose but to inflame the jury and should therefore have been excluded under Evid. See id. Appellants objected to the admission of the video.. 000 Trial Tactician 555.3d 444. We have held that a properly authenticated video of a ―day in the life‖ of an injured plaintiff may be admitted into evidence to aid the jury in understanding the nature and extent of the plaintiff‘s injuries. 000 Ohio St.

Stonewall Jackson. MCKINLEY.. See page 146. confusion of issues. Evid.J. C. 403. and GARFIELD. {¶ 39} Appellants‘ argument is rejected. such as the brain-injury center where she was then residing. for appellants. concur. MILLARD FILLMORE. or at a different facility that costs less than $250 per day. The remainder of the judgment is affirmed. retired. Foe was reckless. Because there was no showing that Dr. the award of punitive damages against him is reversed. This paragraph is an example of a disposition that explains a splintered judgment. CONCLUSION {¶ 40} Having reviewed the arguments and the record in this case. TAFT. Hayes.. of the Nineteenth Appellate District. Sturgess at 360. Rutherford B. urging affirmance for amicus curiae XYZ Group. GRANT. The videotape was the only means the jury had to observe Jane‘s present condition and the medical care being provided to her. urging reversal for amicus curiae ABC Association. Judgment affirmed in part and reversed in part. for appellees. or misleading the jury. __________________ James K. which charged $600 per day. Chester Arthur. The video assisted the jury in resolving the hotly contested issue of whether Jane requires care at a longterm-care facility. Acting C. sitting for HAYES.R.. Polk. The Supreme Court of Ohio 148 Writing Manual . III.evidence was not substantially outweighed by the risk of undue prejudice. COOLIDGE. JJ.J. J. CLEVELAND. we affirm the judgment of the court of appeals in part and reverse it in part.

etc. and this cause is remanded to the trial court for a hearing on prejudgment interest. HOW TO WRITE GENERAL DISPOSITIONS The cause is remanded to the trial court for entry of judgment for appellants. A remand ―for further proceedings consistent with this opinion‖ is not recommended. and the cause is remanded to that court for consideration of Assignment of Error No. This usually occurs in the final paragraph of the opinion.. The writer should be careful to be precise and thorough so that the lower court and the parties understand what. If the judgment of the court of appeals is being reversed and the cause remanded. whether it is affirming. We reverse the judgment of the court of appeals and reinstate the judgment of the trial court. We reverse the judgment of the court of appeals and enter final judgment for appellant. they are being ordered to do and so that the parties and their counsel are clearly apprised of the result. It is also critical to state what the court is expected to do on remand. Be specific. The court of appeals‘ judgment is vacated. General Dispositions. Accordingly.e. The Supreme Court of Ohio 149 Writing Manual . In general dispositions.2. A majority opinion must contain a description of the action the court is taking. reversing and remanding. reversing. be clear and thorough. The court of appeals‘ judgment is reversed. the judgment of the court of appeals is reversed. 20.SECTION TWENTY: DISPOSITIONS ______________________________________________________ 20. III. it is important to clarify which court is receiving the remand. Johnson. The cause is remanded to the trial court for resentencing consistent with State v. i. Overview. and the cause is remanded to the trial court for an award of reasonable attorney fees to appellant.1. if anything.

and we remand this cause to the court of appeals for a review of the award in light of our holding in Arbino. and the defendant is discharged. We therefore reverse the judgment of the court of appeals and reinstate the trial court‘s order granting a new trial. We affirm the portion of the judgment holding that venue was proper. i. When the judgment is splintered. explain the result clearly by identifying which portions of the judgment are affirmed and which are reversed. Therefore. we reverse the portion of the judgment upholding the award of punitive damages. The Supreme Court of Ohio 150 Writing Manual . The judgment of the court of appeals is reversed. We reverse the judgment of the court of appeals on the award of treble damages under the Telephone Consumer Protection Act and remand this cause to the trial court for application of the ―knowingly‖ standard of conduct to these facts.HOW TO WRITE GENERAL DISPOSITIONS (CONT. we affirm in part and reverse in part.3. We affirm the court of appeals‘ judgment insofar as it upholds the finding of liability. however. when it affirms in part and reverses in part. but we reverse that part of the judgment upholding the damages award. Splintered Judgments. and the cause is remanded to that court for a resolution on the merits. However..e. 20. we affirm the judgment of the Franklin County Court of Appeals on the denial of attorney fees under the Consumer Sales Practices Act. This cause is remanded to the trial court for retrial on the issue of damages only. we affirm the appellate court with respect to its ruling that agency by estoppel does not apply.) The judgment of the appellate court dismissing appellant‘s appeal as untimely is reversed. HOW TO WRITE SPLINTERED JUDGMENTS Based on the foregoing.

and respondents are ordered to certify Richard Roe as a candidate for the office of mayor of the village of Anytown. Respondents are ordered to provide access to the requested investigative records. For cases in which the court orders a party or parties to act. specificity is crucial. HOW TO WRITE JUDGMENTS ORDERING PARTIES TO ACT The writ is granted in part and denied in part. The Supreme Court of Ohio 151 Writing Manual .4. Judgments Ordering Parties to Act. Be clear and precise. 2006. identifying exactly what act is required and of whom. We order the Industrial Commission to vacate its order and issue a new order allowing temporary total disability benefits from July 23.20. The writ of mandamus is granted. to October 2. but they may not release those parts that contain identifying information regarding uncharged suspects. 2005.

The Supreme Court of Ohio 152 Writing Manual .

For example.) but not with the reasoning of the majority opinion. expand upon. Separate opinions serve several functions. or clash with the views of the majority. concurring in judgment only) (―While I agree with the ultimate resolution. A judge who writes a separate concurrence might do so simply to express his or her agreement.. e. that opinion is a dissent.g. reversal. 151-152. 89 Ohio St. Auto.3d 95.g. Generally. J. For instance.2.g.E. Ins. Co. e. I do not subscribe to the majority‘s reliance on Cicco v. 89 Ohio St. that the statute in question raises serious constitutional concerns in other contexts). etc. reverse. Leisure v.E.) but not with the reasoning supporting that result.3d 110. but often concurrences are written for other reasons. See. a concurring judge might write to emphasize a certain point or to articulate additional grounds supporting the majority that were not expressed in the majority opinion. that the jury instructions were flawed or that the indictment was faulty. If the writer agrees with the result (i. the judge writing this type of separate opinion would agree that the conviction should be reversed.2d 1078 (2000) (Douglas. but often a concurring opinion will express different reasons for the same result.. affirmance. A.e.3d 146. 572 N.2d 1066. State Farm Mut. If the writer agrees with the principles expressed in the majority opinion but disagrees with the result. Categories.. 728 N.. 111.. Concurring in judgment only An opinion concurring in judgment only is meant to convey that the writing judge agrees with the result (affirm.SECTION TWENTY-ONE: SEPARATE OPINIONS ______________________________________________________ 21. views that elucidate.1. It might agree with the reasoning as well. State v. J.. the opinion is a concurrence. They offer additional or contradictory points that may be of use to future courts reconsidering the issue.E. 728 N. Stockmaster (2000). in disposing The Supreme Court of Ohio 153 Writing Manual . concurring) (agreeing with the majority but writing separately to emphasize a point touched on by the majority opinion. 21. 59 Ohio St. e. Concurring A concurring opinion agrees with the judgment of the majority.2d 59 (1991) (Wright. but not for the reason advanced by the majority. The majority opinion may even be improved by its response to points brought up in a separate opinion. Shedrick.. See. B. They express the specific views of the writers. etc. The main factor that determines the appropriate label for a separate opinion is whether the author agrees with the judgment of the majority. if the majority decides to reverse because the court of appeals incorrectly upheld a criminal conviction based on a faulty indictment. but for a different reason.

I continue to adhere to my dissent therein‖). For an example. In other words. Claytor. Other categories These are the four main categories of separate opinions.3d 185. accordingly.2d 472 (1991) (Resnick. The most common is Concurring in syllabus and judgment – See. Most separate opinions fall into one of the four. I believe that Cicco was not properly decided and.E. C. The ―concurring‖ and ―dissenting‖ points in this kind of opinion relate only to the judgment. but disagreeing with the application of that principle to the case before the court).g. concurring in part and dissenting in part) (―I concur with the majority in the affirmance of the convictions.J. D. 18 Ohio St. 574 N. 697 N. 247. see State v... Morgan v. 83 Ohio St. 480 N. Others exist that are used less often.. E.E. The Supreme Court of Ohio 154 Writing Manual . but must respectfully dissent from its reversal of the death penalty‖). but to be properly labeled a dissent.. e. See.g.3d 24. dissenting) (disagreeing with the majority‘s reversal of the judgment of the court of appeals and expressing the belief that the appellate court did not err in refusing to apply the doctrine of res ipsa loquitur). e. Concurring in part and dissenting in part This type of separate opinion is fully described in its label...E. Children’s Hosp.of this matter. Dissenting A dissenting opinion is written to express disagreement with the majority. 61 Ohio St.2d 464 (1985) (Holmes. A dissenter may agree with some of the majority‘s analysis. C. the opinion must disagree with the judgment. an opinion that concurs wholly in the judgment cannot be labeled a concurrence in part and dissent in part. 190-192. J. J. concurring in syllabus and judgment) (agreeing with the majority‘s judgment answering the certified question in the affirmative and with the principle expressed in the syllabus. 34. Cleveland.2d 610 (1998) (Moyer.3d 234. Cater v.

INDEX _____________________________________________________
A
Abbreviations Federal rules, 49 Months, 76 Ohio reporters, 19, 20 Ohio statutes, 41 Ohio Supreme Court rules, 47 Out-of-state reporters, 27, 32 Out-of-state statutes, 44 Style or citation of a case, 76-83 West's regional reporters, 33, 34 Accord, 65 Acronyms Defintion of, 105 Identification of, 105 Overuse of, 105 Administrative Code, Ohio, 49 Administrative decisions, Ohio, 18, 19 Administrative Regulations, 49, 50 American Jurisprudence, 55 Annotations, 55 Appellate cases, Ohio, 7 Non-print published cases, 10 Print published cases, 7 Appellees, definition of, 109 Attorney General opinions, Ohio, 56 Authorial discretion in judicial opinions, 127 Captions, ix, 5, 10-19, 21-26, 35, 107, 108 Consolidated cases, 110 Cross-appeals, 109 Formal, 103 Miscellaneous, 109 Original actions, 110 Cases Ohio, 5 Out-of-state, 24-26 cf., 66 Circuit courts, 22 Citation omitted, 69, 70 Cite-as line, 108, 109 Code of Federal Regulations, 50 Commonly misused words and phrases, 115-121 Compare, 66 Compare...with, 67 Concurring opinion, 153, 154 Consolidated cases, captions of, 110 Constitutional amendments, 40, 93 Constitutions, 39 Contra, 67 Corpus Juris, Corpus Juris Secundum, 55 Courts of appeal, 7, 10, 11, 15, 16, 17 Cross-appeals, captions of, 109

D
Dates in text, 91 Dictionary, 51, 52, 53 Dispositions General, 149, 150 Judgements ordering parties to act, 151 Overview, 149 Splintered judgements, 150 Dissenting opinions, 154 District courts, 23 Districts, Ohio Appellate List, 9 Map, 8
155 Writing Manual

B
Bankruptcy Reports, 23 Block Quotations, 99, 100 But see, 67, 68

C
Capitalization Proper nouns, 89 Public offices, agencies, and entities, 90 Titles of persons, 89

The Supreme Court of Ohio

E
E.g., 68, 69 Ellipses, 99 Encyclopedias, 55, 56 Emphasis, 73, 74, 103 Explanatory Case History, 70, 71

J
Judgment Ordering Party to Act, 151 Judicial opinion Example 1, Civil Case, Single Issue, 132 Example 2, Criminal Case, Two Issues, 135 Example 3, Civil Case, Multiple Issues, Divided by Headings, 140 Outline of, 129, 130 Structure of, 125 Judicial opinions Sample of, 131 Juveniles, references to, 111

F
Federal Cases, 21 Register, 50 Regulations, 50 Rules, 49 Footnotes Citations in, 101 Numerals Relating to Punctuation, 99 Placement of superscript, 95 Use of, 101 Foreign cases, 34 Formal case captions, 107

L
Law reviews, 53, 54 Legislative Acts, 42 Lexis citations, 11, 12, 13, 16, 19, 22, 24, 26, 35, 36, 53, 131 Lists Parallelism of, 97 Punctuation of, 97 Local rules of court, 48

H
Headings Form of, 113 Use of, 113 Headnotes, 131 History of case, 70

M
Magazines, 56 Misused words and phrases, 115-121 Months of the year, abbreviations, 76 Municipal ordinances, 43

I
Id., 83, 84 In the Matter of, 109 Infra, 83, 84 Internal quotations, 70 Internet, 57 Introduction to Part I, Manual of Citations, 3 Introduction to Part II, Style Guide, 87 Introduction to Part III, Structure of a Judicial Opinion, 125 Italics For emphasis, 73, 103 Overuse of, 103 Reverse, 103 Use, 103

N
Names Months, 76 Offices or organizations, 90 Newspapers, 56 Numbers, 93, 94, 95

O
Ohio appellate cases Decided before May 1, 2002, 10, 11 Decided on or after May 1, 2002, 15, 16

The Supreme Court of Ohio

156

Writing Manual

Ohio Appellate Districts List, 9 Map, 8 Ohio Attorney General opinions, 56 Ohio Bar Reports, 10 Ohio cases, 5 Ohio Citations at a Glance, 35 Ohio Constitution, 39 Ohio Jurisprudence, 56 Ohio Legislative Acts, 42 Ohio Municipal Ordinances, 43 Ohio Official Reports, 3, 131 Ohio Opinions, 10 Ohio Supreme Court cases Decided before May 1, 2002, 5, 6 Decided on or after May 1, 2002, 14 Ohio trial court cases Decided before May 1, 2002, 11, 12, 13 Decided on or after May 1, 2002, 16, 17, 18 Ordinances, 41 Original actions, 110 Outline of judicial opinion, 129 Out-of-state court cases, 24, 25, 26

R
Regulations Federal, 49 Ohio, 49 Restatements, 51 Reverse italics,103 Rules Federal, 49 Ohio, 47, 48 Local, 48

S
Sample judicial opinions, 132 Secondary sources, 51 See, 65 See also, 65, 66 See generally, 68 See, e.g.,, 69 Separate opinions, generally, 153 Short-form citations, 59-62 Signal words, 63, 64 Spacing within parentheses Abbreviated words, 75 Names of months, 76 Ordinal numbers, 75 Unabbreviated words, 75 Statutes Federal, 43 Foreign, 45 Out-of-state, 44, 45 Structure of a Judicial Opinion, 123 Subsequent history, 70, 17 Supra, 83, 84 Syllabus, 131 Style Guide, 85

P
Parallelism in lists, 97 Parenthetical References, 106 Placement of citation, 72 Preface, ix Professional titles, capitalization of, 89 Public agencies, capitalization of, 90 Public offices, capitalization of, 90 Public-domain citations, 26 Punctuation, 97

Q
Quotation marks, placement of, 97, 98 Quotations Attribution of, 70 Block, 99, 100 Internal, 70 Punctuation of, 98

T
Texts, 51, 52, 53 Titles of entities, capitalization of, 90 Titles of persons, capitalization, 89 Treatises, 51, 52, 53

The Supreme Court of Ohio

157

Writing Manual

11. 18. 7. 131 Words within parentheses. 11. 34. 21 W Web sites. 24. 5. 13. 37.U United States Code. 12. 76 The Supreme Court of Ohio 158 Writing Manual . 53. 14-18 West regional reporters. 44 United States Constitution. 43. 75. 26. ix. 33. 131 Westlaw citations. 57 WebCites. 40 United States Supreme Court.

.

Ohio 43215-3431 .The Supreme Court of Ohio 65 South Front Street Columbus.

Sign up to vote on this title
UsefulNot useful