WRITING MANUAL - Supreme Court - State of Ohio

HOW TO USE COMMON SIGNALS
See Haverlack v. Portage Homes, Inc., 2 Ohio St.3d 26, 442 N.E.2d 749
(1982), paragraph two of the syllabus. See also Enghauser Mfg. Co. v.
Eriksson Eng. Ltd., 6 Ohio St.3d 31, 33, 451 N.E.2d 228 (1983), citing
Russell v. Men of Devon, 2 T.R. 667, 672-673, 100 Eng.Rep. 359 (1788).
Accord Superior Uptown, Inc. v. Cleveland, 39 Ohio St.2d 36, 40-41, 313
N.E.2d 820 (1974).
See, e.g., People v. Honeycutt, 20 Cal.3d 150, 141 Cal.Rptr. 698, 570
P.2d 1050 (1977); see also State v. White, 15 Ohio St.2d 146, 239 N.E.2d
65 (1968); see generally State v. Barker, 8 Ohio St.3d 39, 457 N.E.2d
312 (1983).
D. 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, no signal word is necessary. In other situations, however,
e.g., when a citation provides indirect support for a statement, contradicts it, or
provides a useful comparison, signal words are used to explain the level of
support or contradiction that the cited authority provides. As the examples below
suggest, when using a signal word, consider including a parenthetical that clarifies
why the case is being cited and why the signal is appropriate.
1. No signal
Use no signal before a citation when the citation provides direct support.
In other words, use no signal when you are quoting or paraphrasing
language from the source or you are identifying a source referred to in the
text.
The Supreme Court of Ohio 64 Writing Manual