State v. Sanders, 761 N.E.2d 18 (Ohio 2002). · Go Syfert
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State v. Sanders, 761 N.E.2d 18 (Ohio 2002). Cases Citing This Book View Copy Cite
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cited 45× by 45 distinct cases, 2016–2026→ Stable · …a reasonable probability is a probability sufficient to undermine confidence in the outcome. at p. 151 ✓ Topic ↗
cited 8× by 8 distinct cases, 2013–2024 · …there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. ✓
cited 6× by 6 distinct cases, 2017–2021 · …when a convicted defendant complains of the ineffectiveness of counsel's assistance, the defendant must show that the counsel's representation fell below an objective standard of reasonableness. ✓
282 citation events (282 in the last 25 years) across 3 distinct courts.
Strongest positive: State v. Freiburger (ohioctapp, 2026-05-29)
Treatment trajectory · 2001 → 2026 · click a year to view as-of
2001 2013 2026
Top citers, strongest first. 29 distinct citers. How cited ↗
discussed Cited as authority (rule) State v. Freiburger
Ohio Ct. App. · 2026 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 51} Given our resolution of Freiburger’s second, third, and fourth assignments of error, we find that Freiburger cannot establish either prong of a claim of ineffective assistance of counsel.
cited Cited as authority (rule) State v. Koonce
Ohio Ct. App. · 2026 · confidence medium
State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
discussed Cited as authority (rule) State v. Sweet
Ohio Ct. App. · 2026 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 21} Properly licensed Ohio lawyers are presumed competent.
discussed Cited as authority (rule) State v. Street
Ohio Ct. App. · 2026 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). 8. {¶ 18} Properly licensed Ohio lawyers are presumed competent.
cited Cited as authority (rule) State v. Elston
Ohio Ct. App. · 2026 · confidence medium
State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
discussed Cited as authority (rule) State v. Cornelious
Ohio Ct. App. · 2026 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 104} Properly licensed Ohio lawyers are presumed competent.
discussed Cited as authority (rule) State v. Prichard
Ohio Ct. App. · 2026 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 59} Having determined that the erroneous admission of the bill of sale constituted harmless error, it follows that Prichard cannot show that there was a reasonable probability of a different outcome had defense counsel raised additional objections to its admission or had not produced the document in the first place.
cited Cited as authority (rule) State v. Harris
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
cited Cited as authority (rule) State v. Rosas
Ohio Ct. App. · 2025 · confidence medium
State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
cited Cited as authority (rule) State v. Hall
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
discussed Cited as authority (rule) State v. Harris
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 91} Properly licensed Ohio lawyers are presumed competent.
cited Cited as authority (rule) State v. Rutledge
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
cited Cited as authority (rule) State v. Hinckley
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
cited Cited as authority (rule) State v. Thieman
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
discussed Cited as authority (rule) State v. Hall
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 34} Properly licensed Ohio lawyers are presumed competent.
discussed Cited as authority (rule) State v. Kinney
Ohio Ct. App. · 2025 · confidence medium
“A 36. reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 86} Properly licensed Ohio lawyers are presumed competent.
discussed Cited as authority (rule) State v. Quinn
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 62} Properly licensed Ohio lawyers are presumed competent.
discussed Cited as authority (rule) State v. Haas
Ohio Ct. App. · 2025 · confidence medium
“A reasonable probability is a probability sufficient to undermine confidence in the outcome.” State v. Sanders, 94 Ohio St.3d 150, 151 (2002). {¶ 54} Properly licensed Ohio lawyers are presumed competent.
cited Cited as authority (rule) State v. Sandifur
Ohio Ct. App. · 2024 · confidence medium
State v. Sanders, 94 Ohio St.3d 150, 151 (2002).
discussed Cited as authority (rule) Franklin v. Anderson
6th Cir. · 2006 · confidence medium
See State v. Mack, 805 N.E.2d 1108 , 1109 (Ohio 2004); State v. Goff, 784 N.E.2d 700, 701 (Ohio 2003); State v. Mitts, 784 N.E.2d 698 , 699-700 (Ohio 2003); State v. Bryant-Bey, 776 N.E.2d 480 , 481-82 (Ohio 2002); State v. Sneed, 774 N.E.2d 1216 , 1217-18 (Ohio 2002); State v. Davie, 772 N.E.2d 119 , 120-21 (Ohio 2002); State v. Smith, 766 N.E.2d 588, 589-90 (Ohio 2002); State v. Sanders, 761 N.E.2d 18, 19-20 (Ohio 2002).
discussed Cited as authority (rule) George T. Franklin, Petitioner-Appellee/cross-Appellant v. Carl S. Anderson, Warden, Respondent-Appellant/cross-Appellee (2×)
6th Cir. · 2006 · confidence medium
See State v. Mack, 101 Ohio St.3d 397 , 805 N.E.2d 1108 , 1109 (2004); State v. Goff, 98 Ohio St.3d 327 , 784 N.E.2d 700, 701 (2003); State v. Mitts, 98 Ohio St.3d 325 , 784 N.E.2d 698 , 699-700 (2003); State v. Bryant-Bey, 97 Ohio St.3d 87 , 776 N.E.2d 480 , 481-82 (2002); State v. Sneed, 96 Ohio St.3d 348 , 774 N.E.2d 1216 , 1217-18 (2002); State v. Davie, 96 Ohio St.3d 133 , 772 N.E.2d 119 , 120-21 (2002); State v. Smith, 95 Ohio St.3d 127 , 766 N.E.2d 588, 589-90 (2002); State v. Sanders, 94 Ohio St.3d 150 , 761 N.E.2d 18, 19-20 (2002).
discussed Cited "see" State v. Horner, L-07-1224 (11-26-2008)
Ohio Ct. App. · 2008 · signal: see · confidence high
"Second, `the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty.'" Xie , at 524 ; quoting Hill , at 59 ; see Strickland , at 687 . {¶ 15} Appellant asserts that his attorney at the time of entering his plea, was ineffective in failing to secure the promise of a reduced sentence prior to the plea. {¶ 16} "A court must indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance." State v. Sanders (2002), 94 Ohio St.3d 150 , 151 , 2002-Ohio-350 ; quoting Strickland…
discussed Cited "see" State v. Sanders, Unpublished Decision (9-27-2002) (2×)
Ohio Ct. App. · 2002 · signal: see · confidence high
See State v. Sanders , 94 Ohio St.3d 150 , 2002-Ohio-350 , 761 N.E.2d 18 . {¶ 3} In May of 2001, the appellant filed his second postconviction petition and a number of related motions, including a "Motion to Declare Ohio Revised Code Section 2953.23 Unconstitutional." By separate entries dated January 15, 2002, the common pleas court dismissed the second postconviction petition and overruled the various motions, and the appellant appealed. {¶ 4} On appeal, the appellant advances four assignments of error.
discussed Cited "see" State v. Sneed (2×)
Ohio · 2002 · signal: see · confidence high
See Jones v. Barnes (1983), 463 U.S. 745 , 103 S.Ct. 3308 , 77 L.Ed.2d 987 .” State v. Sanders (2002), 94 Ohio St.3d 150, 151-152 , 761 N.E.2d 18 . 2 January Term, 2002 {¶8} We have reviewed appellant’s three propositions of law alleging, inter alia, deficient performance by appellate counsel.
discussed Cited "see" State v. Sneed (2×)
Ohio · 2002 · signal: see · confidence high
See Jones v. Barnes (1983), 463 U.S. 745 , 103 S.Ct. 3308 , 77 L.Ed.2d 987 .” State v. Sanders (2002), 94 Ohio St.3d 150, 151-152 , 761 N.E.2d 18 .
discussed Cited "see, e.g." State v. Huckleby
Ohio Ct. App. · 2018 · signal: see also · confidence low
See also State v. Bradley, 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶ 28} As the Supreme Court of Ohio instructed in State v. Sanders, 94 Ohio St.3d 150 , 761 GALLIA, 16CA15 & 16CA16 12 N.E.2d 18 (2002), “Strickland charges us to ‘[apply] a heavy measure of deference to counsel's judgments,’ 466 U.S. at 691 , 104 S.Ct. at 2066 , 80 L.Ed.2d at 695 , and to ‘indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance,’ id. at 689 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694 . * * * [W]e n…
examined Cited "see, e.g." State v. Ferguson (3×)
Ohio Ct. App. · 2018 · signal: see also · confidence low
See also State v. Bradley , 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶ 13} As the Supreme Court of Ohio instructed in State v. Sanders , 94 Ohio St.3d 150 , 761 N.E.2d 18 (2002), " Strickland charges us to '[apply] a heavy measure of deference to counsel's judgments,' 466 U.S. at 691 , 104 S.Ct. at 2066 , 80 L.Ed.2d at 695 , and to 'indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance,' id. at 689 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694 . * * * [W]e note that courts must 'judge the re…
discussed Cited "see, e.g." State v. Storms (2×)
Ohio Ct. App. · 2017 · signal: see also · confidence low
See also State v. Bradley , 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶ 17} The Supreme Court of Ohio instructed in State v. Sanders , 94 Ohio St.3d 150 , 761 N.E.2d 18 (2002), " Strickland charges us to '[apply] a heavy measure of deference to counsel's judgments,' 466 U.S. at 691 , 104 S.Ct. at 2066 , 80 L.Ed.2d at 695 , and to 'indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance,' Id. at 689 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694 . * * * [W]e note that courts must 'judge the reaso…
discussed Cited "see, e.g." State v. Williams (2×)
Ohio Ct. App. · 2017 · signal: see also · confidence low
See also State v. Bradley, 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶ 20} As the Supreme Court of Ohio instructed in State v. Sanders, 94 Ohio St.3d 150 , 761 N.E.2d 18 (2002), “Strickland charges us to ‘[apply] a heavy measure of deference to counsel's judgments,’ 466 U.S. at 691 , 104 S.Ct. at 2066 , 80 L.Ed.2d at 695 , and to ‘indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance,’ id. at 689 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694 . * * * [W]e note that courts must ‘jud…
Retrieving the full opinion text from the archive…
The State of Ohio
v.
Sanders, n.k.a. Hasan
No. 99-536.
Ohio Supreme Court.
Jan 30, 2002.
761 N.E.2d 18
Mark C. Piepmeier, Special Prosecuting Attorney, and William E. Breyer, Assistant Special Prosecuting Attorney, for appellee., Patricia A. Millhoff, for appellant.
Cook, Douglas, Moyer, Pfeifer, Resnick, Stratton, Sweeney.
Cited by 147 opinions  |  Published
Per Curiam.

Appellant, Carlos Sanders, n.k.a. Siddique Abdullah Hasan, challenges the denial of his application to reopen his direct appeal under App.R. 26(B).

Sanders was sentenced to death for the aggravated murder of Correctional Officer Robert Vallandingham. The Court of Appeals for Hamilton County affirmed his convictions and sentences. State v. Sanders (May 1,1998), Hamilton Ap9//9876. No. C-960253, unreported, 1998 WL 212756. We affirmed the court of appeals’ judgment. State v. Sanders (2001), 92 Ohio St.3d 245, 750 N.E.2d 90.

On July 24, 1998, Sanders filed his App.R. 26(B) application in the court of appeals. That court denied the application, holding that Sanders had failed to show the existence of a genuine issue as to whether he had been denied the effective assistance of counsel on appeal. State v. Sanders (Feb. 4, 1999), Hamilton App. No. C-960253, unreported.

App.R. 26(B)(5) requires that the applicant show “a genuine issue as to whether the applicant was deprived of the effective assistance of counsel on appeal.” As the court of appeals recognized, Strickland v. Washington (1984), 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674, sets forth the standard for judging ineffective-assistance claims. “When a convicted defendant complains of the ineffectiveness of counsel’s assistance, the defendant must show that counsel’s representation fell below an objective standard of reasonableness.” Id. at 687-688, 104 S.Ct. at 2064, 80 L.Ed.2d at 693. Furthermore, “[t]he defendant must show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id. at 694, 104 S.Ct. at 2068, 80 L.Ed.2d at 698. See, also, State v. Bradley (1989), 42 Ohio St.3d 136, 538 N.E.2d 373, paragraphs two and three of the syllabus.

Strickland charges us to “[apply] a heavy measure of deference to counsel’s judgments,” 466 U.S. at 691, 104 S.Ct. at 2066, 80 L.Ed.2d at 695, and to “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance,” id. at 689, 104 S.Ct. at 2065, 80 L.Ed.2d at 694. Moreover, we must bear in mind that appellate counsel need not raise every[*152] possible issue in order to render constitutionally effective assistance. See Jones v. Barnes (1983), 463 U.S. 745, 103 S.Ct. 3308, 77 L.Ed.2d 987.

Mark C. Piepmeier, Special Prosecuting Attorney, and William E. Breyer, Assistant Special Prosecuting Attorney, for appellee. Patricia A. Millhoff, for appellant.

Finally, we note that courts must “judge the reasonableness of counsel’s challenged conduct on the facts of the particular case, viewed as of the time of counsel’s conduct.” Strickland, 466 U.S. at 690, 104 S.Ct. at 2066, 80 L.Ed.2d at 695.

The two-part Strickland test “is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5).” State v. Spivey (1998), 84 Ohio St.3d 24, 25, 701 N.E.2d 696, 697. Applying Strickland, we agree with the court of appeals’ conclusion that Sanders has failed to raise a genuine issue of ineffective assistance of counsel.

Accordingly, we affirm the judgment of the court of appeals.

Judgment affirmed.

Moyer, C.J., Douglas, Resnick, F.E. Sweeney, Pfeifer, Cook and Lundberg Stratton, JJ., concur.