Case Citator › Adomeit v. Baltimore

Adomeit v. Baltimore

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Ohio Court of Appeals
Citation
316 N.E.2d 469
Decided
Confirmed treatments
1
Flagged citations read
66 of 66
Citing cases (total)
66
Treatment dates
1977
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Adomeit v. Baltimore has been limited: an Ohio appeals court declined to extend its requirement to show a valid defense to a challenge to a judgment entered after trial. All 66 flagged citations have been read, and the one confirmed limitation is listed below.
More on how this was screened

Later Ohio opinions continue to apply Adomeit's standards for when a hearing on relief from judgment is required.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

66 later cases cite Adomeit v. Baltimore; 66 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 Adomeit v. Baltimore?

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.

Treatments

Limited

  • The Ohio Court of Appeals declined to extend Adomeit's valid-defense requirement beyond its default-judgment setting to a Rule 60(B)(3) challenge after trial.

    Advance Mortgage Corp. v. Novak · Ohio Court of Appeals · filed

    Although the court in Adomeit, supra, noted that Civil Rule 60(B) applies to the vacation of all judgments, including cognovit judgments, default judgments, summary judgments, and judgments after trial, the concern of the court in that case was limited to a motion for vacation of a default judgment. ... The courts in Ohio have not addressed the issue as to whether it is necessary, after trial in a 60 (B)(3) proceeding, to allege a defense. We hold that the assertion of a valid defense is not required in such cases.
    Read the full opinion on CourtListener →

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