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Case Citations [i] (Spring 2026)

handle is hein.ali/retpwodt9957 and id is 1 raw text is: THE AMERICAN LAW INSTITUTE Spring 2026 Citations PROPERTY 3D (WILLS AND OTHER DONATIVE TRANSFERS) DIVISION I. PROBATE TRANSFERS (WILLS AND INTESTACY) CHAPTER 1. DEFINITIONS AND BASIC PRINCIPLES § 1.2 Requirement of Surviving the Decedent Ohio, 2024. Com. (a) cit. in case cit. in diss. op. Member of township board of trustees filed a defamation claim against real-estate developer, alleging that defendant sent himself an email from a fictitious email account that falsely portrayed plaintiff as having accepted an illegal payment from defendant, and showed the email to others both immediately and again nearly a decade later. The trial court granted summary judgment for defendant based on the statute of limitations. The court of appeals reversed. This court affirmed, holding that the discovery rule applied because the publication of the email was secretive, concealed, or otherwise inherently unknowable to plaintiff, and that, under the rule, plaintiff s defamation claim accrued when he discovered the email. A dissent argued that the majority's application of the discovery rule to defamation cases was contrary to state precedent, which was reluctant to disturb well-established law regarding the accrual date for defamation causes of action, and failed to consult the common-law principles contained in the Restatement like it had previously done in other cases, including Restatement Third of Property: Wills and Other Donative Transfers § 1.2. Weidman v. Hildebrant, 254 N.E.3d 2, 34. DIVISION III. PROTECTIVE DOCTRINES CHAPTER 8. INVALIDITY DUE TO THE DONOR'S INCAPACITY OR ANOTHER'S WRONGDOING PART B. PROTECTION AGAINST WRONGDOING § 8.3 Undue Influence, Duress, or Fraud COPYRIGHT C2026 By THE AMERICAN LAW INSTITUTE All rights reserved Printed in the United States of America For earlier citations, see the Appendices, Supplements, or Pocket Parts, if any, that correspond to the subject matter under examination.