Eastley v. Volkman
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Later Ohio courts overwhelmingly followed Eastley's distinction between evidentiary sufficiency and manifest weight and its framework for manifest-weight review. The repeated word “overruled” ordinarily disposed of an assignment of error or described Eastley's effect on earlier authority; “superseded” and “disapproved” likewise concerned other cases. The Eighth District in State v. Reillo, and a later Fifth District opinion relying on it, briefly rejected Eastley's direction to defer to factfinder credibility determinations. The Supreme Court of Ohio then reversed Reillo in 2026-Ohio-2701 and expressly held that Eastley paragraph 21 is law that reviewing courts must apply, so those displaced departures do not supply live adverse entries.
2,407 later cases cite Eastley v. Volkman; 135 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Eastley v. Volkman?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
No reviewed court has overruled or limited this case.
Every one of the 135 flagged citations was read, and each turned out to be something other than adverse treatment: a routine application, a party's argument the court rejected, or the case itself discussing older law. That reading is the finding this page exists to report.
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