Case Citator › Seasons Coal Co. v. City of Cleveland

Seasons Coal Co. v. City of Cleveland

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

Criticized by some courts
Court
Supreme Court of Ohio
Citation
10 Ohio St. 3d 77
Decided
Confirmed treatments
1
Flagged citations read
289 of 289
Citing cases (total)
5,000
Treatment dates
2024
Criticized by some courts
At least one reviewed court has criticized this case’s reasoning. No reviewed court has overruled it. Criticized; the governing rule was reaffirmed in 2026. All 289 flagged citations have been read.
More on how this was screened

The historical criticism in State v. Butler is listed below. It adopted a view that the Supreme Court of Ohio subsequently rejected in State v. Reillo, 2026-Ohio-2701 — — filed 2026-07-17. That controlling decision expressly invokes Seasons Coal and holds that appellate courts reviewing criminal manifest-weight challenges must give deference to the fact-finder’s credibility determinations. source

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.

5,000 later cases cite Seasons Coal Co. v. City of Cleveland; 289 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 Seasons Coal Co. v. City of Cleveland?

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

Criticized

  • The Fifth District adopted criticism of applying Seasons Coal’s deference presumption in criminal manifest-weight review; the Ohio Supreme Court later rejected that position.

    State v. Butler · Court of Appeals of Ohio, Fifth Appellate District · filed

    Traditionally courts have found that in weighing the evidence, the court of appeals “must always be mindful of the presumption in favor of the finder of fact.” Eastley v. Volkman, 2012-Ohio-2179, ¶ 21. “The underlying rationale of giving deference to the findings of the trial court rests with the knowledge that the [trier of fact] is best able to view the witnesses and observe their demeanor, gestures and voice inflections, and use these observations in weighing the credibility of the proffered testimony.” Seasons Coal Co., Inc. v. Cleveland, 10 Ohio St.3d 77, 80 (1984). … In reality, “[i]If appellate panels defer to the trier of fact’s credibility determinations, which resulted … in the finding of guilt or there would not be an appeal, there would be no reason to advance a manifest-weight challenge.” Id.
    Read the full opinion on CourtListener →

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