Ohio has only briefly addressed the entrance of Bell Atlantic onto the pleading stage, and, thus far, Ohio state courts have mostly retained the Conley standard for determining pleadings. However, multiple pleading standards are emerging, making the issue ripe for a determination by the Supreme Court of Ohio as to what the true pleading standard is for Ohio. This Note will explain why Ohio should preserve Conley, even if doing so diverges from the original intent of federal-state uniformity embodied by the Federal Rules of Civil Procedure.
Note, Pleading in Ohio after Bell Atlantic v. Twombly and Ashcroft v. Iqbal: Why Ohio Shouldn't Notice a Change, 58 Clev. St. L. Rev. 495 (2010)