Case Citator › Westfield Insurance v. Galatis

Westfield Insurance v. Galatis

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

Limited by some courts
Court
Supreme Court of Ohio
Citation
100 Ohio St. 3d 216
Decided
Confirmed treatments
3
Flagged citations read
173 of 173
Citing cases (total)
1,062
Treatment dates
2006–2020
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. All 173 flagged citations for Westfield Insurance v. Galatis have been read, and the 3 confirmed treatments are listed below. Sheaffer v. Westfield Insurance held Galatis inapplicable retroactively after an earlier coverage judgment became final.
More on how this was screened

State v. Bodyke confined Galatis's tripartite stare-decisis test to contract, property, and tort law rather than constitutional interpretation, and State v. Henderson later declined to apply that test in criminal sentencing. The other opinions applied Galatis, reported its limitation of Scott-Pontzer and overruling of Ezawa, or used nearby adverse language for litigants' assignments of error and other authorities.

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.

1,062 later cases cite Westfield Insurance v. Galatis; 173 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 Westfield Insurance v. Galatis?

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 Supreme Court of Ohio held that Galatis could not be applied retroactively after denial of jurisdiction made an earlier coverage judgment final.

    Sheaffer v. Westfield Insurance · Supreme Court of Ohio · filed

    Argonaut argues that Galatis should be applied retroactively to foreclose liability because its appeal was pending at the time that Galatis was decided. See Hopkins v. Dyer, 104 Ohio St.3d 461, 2004-Ohio-6769, 820 N.E.2d 329. While Argonaut’s argument is generally correct, it does not apply to the particular facts of this case. When we denied jurisdiction over Sheaffer I, that decided the issue and prevented any retroactive application of Galatis to this case.
    Read the full opinion on CourtListener →

  • The Supreme Court of Ohio confined Galatis's tripartite stare-decisis test to contract, property, and tort cases and held it noncontrolling for constitutional interpretation.

    State v. Bodyke · Supreme Court of Ohio · filed

    Our decision in Galatis, 100 Ohio St.3d 216, 2003-Ohio-5849, 797 N.E.2d 1256, established the test for departing from precedent. But Galatis arose in the context of insurance and contract law, not constitutional law. That difference is significant, as we made clear in our decision in Rocky River, 43 Ohio St.3d at 6-10, 539 N.E.2d 103. In that case, we acknowledged that stare decisis “does not apply with the same force and effect when constitutional interpretation is at issue.”
    Read the full opinion on CourtListener →

  • The Supreme Court of Ohio declined to extend Galatis's three-part stare-decisis test to overruling precedent in the criminal-sentencing context.

    State v. Henderson · Supreme Court of Ohio · filed

    In short, we have been anything but consistent in applying the Galatis test, we are not compelled to apply it here, and we decline to apply it here.
    Read the full opinion on CourtListener →

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