existence of plain error (Ohio) · Go Syfert
← Ohio issues

existence of plain error in Ohio

33 Ohio opinions name it 2 courts 1993–2026 8 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (18)

CaseFollowedCited
State v. Jacintogreen
ohioctapp · 2020 · cited in 3 Ohio opinions naming this issue, 2025–2026
2 sentences

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

2025See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and “will not” guess at undeveloped claims on appeal.’” (Cleaned up.) Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.).

33
State v. Pattongreen
ohioctapp · 2021 · cited in 3 Ohio opinions naming this issue, 2025–2026
2 sentences

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

2025See also State v. Collins, 2008- Ohio-2363, ¶ 91 (8th Dist.) (it is not the duty of this court to develop an argument in support of an assignment of error if one exists); State v. Patton, 2021-Ohio-295, ¶ 25 (1st Dist.) (“An appeals court will not construct a claim of plain error on a defendant’s behalf if the defendant fails to argue plain error on appeal.”). {¶14} Therefore, Chavers’s first assignment of error is overruled.

33
State v. Simsgreen
ohioctapp · 2016 · cited in 3 Ohio opinions naming this issue, 2025–2026
2 sentences

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

33
State v. Coopergreen
ohioctapp · 2007 · cited in 3 Ohio opinions naming this issue, 2016–2017
2 sentences

2017See State v. Cooper , 170 Ohio App.3d 418 , 2007-Ohio-1186 , 867 N.E.2d 493 , ¶ 31 (4th Dist.) ("The defendant carries the burden to establish the existence of plain error, unlike the situation in a claim of harmless error, where the burden lies with the state"). {¶ 15} After Ross filed his appellate brief the Supreme Court of Ohio rejected the Tenth District's analysis in Smith, supra , and reversed the judgments in Mohammad and Mobarak, supra. See State v. Shalash , 148 Ohio St.3d 611 , 2016-Ohio-8358 , 71 N.E.3d 1089 .

2017See State v. Cooper , 170 Ohio App.3d 418 , 2007-Ohio-1186 , 867 N.E.2d 493 , ¶ 31 (4th Dist.) ("The defendant carries the burden to establish the existence of plain error, unlike the situation in a claim of harmless error, where the burden lies with the state"). {¶ 15} After Ross filed his appellate brief the Supreme Court of Ohio rejected the Tenth District's analysis in Smith, supra , and reversed the judgments in Mohammad and Mobarak, supra. See State v. Shalash , 148 Ohio St.3d 611 , 2016-Ohio-8358 , 71 N.E.3d 1089 .

33
State v. Tibbettsgreen
ohio · 2001 · cited in 2 Ohio opinions naming this issue, 2015–2015
2 sentences

2015See State v. Tibbetts, 92 Ohio St.3d 146, 161 (2001) (“Because he failed to object at trial on the specific ground raised here, Tibbetts has forfeited the issue, limiting us to a plain error analysis [of the defendant’s Evid.R. 404(B) argument].”). {¶33} Although Jacobs has preserved plain error review in regard to the Evid.R. 404(B) issue, he has failed to argue the existence of plain error on appeal.

2015See State v. Tibbetts, 92 Ohio St.3d 146, 161 (2001) (“Because he failed to object at trial on the specific ground raised here, [the defendant] has forfeited the issue, limiting us to a plain error analysis [of the defendant’s Evid.R. 404(B) argument].”). {¶9} Although Thomas has preserved plain error review in regard to the Evid.R. 404(B) issue, he has failed to argue the existence of plain error in the admission of this evidence on appeal.

22
State v. Adamsgreen
ohio · 1980 · cited in 2 Ohio opinions naming this issue, 1998–1998
2 sentences

1998See, e.g. , State v. Adams (1980), 62 Ohio St.2d 151 , 153 , 404 N.E.2d 144 ; State v. Long (1978), 53 Ohio St.2d 91 , 372 N.E.2d 804 , paragraph one of the syllabus.

1998See, e.g. , State v. Adams (1980), 62 Ohio St.2d 151 , 153 , 404 N.E.2d 144 ; State v. Long (1978), 53 Ohio St.2d 91 , 372 N.E.2d 804 , paragraph one of the syllabus.

22
State v. Barnesgreen
ohio · 2002 · cited in 4 Ohio opinions naming this issue, 2003–2025
2 sentences

2025“Plain error should be found only in exceptional circumstances and only to prevent a manifest miscarriage of justice.” Id., citing State v. Hill, 92 Ohio St.3d 191, 203 (2001). {¶ 40} McClain has failed to identify the existence of plain error in this case.

2003Given the state of this record, we cannot find the existence of plain error. {¶ 40} In State v. Barnes (2002), 94 Ohio St.3d 21 , 2002-Ohio-68 , the Supreme Court of Ohio recently reiterated the well-established plain error standard by which we are bound in reviewing this claimed error: {¶ 41} "Under Crim.R. 52(B), `plain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.' By its very terms, the rule places three limitations on a reviewing court's decision to correct an error despite the absence of a timely objection at t

14
State v. Thomasgreen
ohioctapp · 2015 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

11
State v. Collins, 89668 (5-15-2008)green
ohioctapp · 2008 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

11
State v. Jonesgreen
· 2018 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

11
State v. Franklin, Unpublished Decision (9-6-2006)green
ohioctapp · 2006 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See, e.g., State v. Sims, 2016-Ohio-4763, ¶ 11 (10th Dist.) (appellant did not meet burden of demonstrating error on appeal where she only preserved plain error and did not argue the existence of plain error on appeal). “‘An appellate court is not obliged to construct or develop arguments to support a defendant’s assignment of error and will not guess at undeveloped claims on appeal.’” Id., quoting State v. Jacinto, 2020-Ohio-3722, ¶ 56 (8th Dist.), see also State v. Collins, 2008-Ohio-2363, ¶ 91 (8th Dist.) (“‘[I]t is not the duty of this Court to develop an argument in support of an assignme

11
State v. Mohamedgreen
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025“The existence of plain error satisfies the prejudice prong of the test for ineffective assistance of counsel.” Jarrell at ¶ 51 , citing State v. Mohamed, 2016-Ohio-1116, ¶ 37 (8th Dist.).

11
State v. Hillgreen
ohio · 2001 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025“Plain error should be found only in exceptional circumstances and only to prevent a manifest miscarriage of justice.” Id., citing State v. Hill, 92 Ohio St.3d 191, 203 (2001). {¶ 40} McClain has failed to identify the existence of plain error in this case.

11
Tye v. Beausaygreen
ohioctapp · 2020 · cited in 1 Ohio opinions naming this issue, 2023–2023
2 sentences

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

11
Ohio Power Co. v. Burnsgreen
· 2022 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

11
State v. Handgreen
ohio · 2016 · cited in 1 Ohio opinions naming this issue, 2017–2017
1 sentence

2017See State v. Cooper , 170 Ohio App.3d 418 , 2007-Ohio-1186 , 867 N.E.2d 493 , ¶ 31 (4th Dist.) ("The defendant carries the burden to establish the existence of plain error, unlike the situation in a claim of harmless error, where the burden lies with the state"). {¶ 15} After Ross filed his appellate brief the Supreme Court of Ohio rejected the Tenth District's analysis in Smith, supra , and reversed the judgments in Mohammad and Mobarak, supra. See State v. Shalash , 148 Ohio St.3d 611 , 2016-Ohio-8358 , 71 N.E.3d 1089 .

11
State v. Shalash (Slip Opinion)green
ohio · 2016 · cited in 1 Ohio opinions naming this issue, 2017–2017
2 sentences

2017See State v. Cooper , 170 Ohio App.3d 418 , 2007-Ohio-1186 , 867 N.E.2d 493 , ¶ 31 (4th Dist.) ("The defendant carries the burden to establish the existence of plain error, unlike the situation in a claim of harmless error, where the burden lies with the state"). {¶ 15} After Ross filed his appellate brief the Supreme Court of Ohio rejected the Tenth District's analysis in Smith, supra , and reversed the judgments in Mohammad and Mobarak, supra. See State v. Shalash , 148 Ohio St.3d 611 , 2016-Ohio-8358 , 71 N.E.3d 1089 .

2017See State v. Cooper , 170 Ohio App.3d 418 , 2007-Ohio-1186 , 867 N.E.2d 493 , ¶ 31 (4th Dist.) ("The defendant carries the burden to establish the existence of plain error, unlike the situation in a claim of harmless error, where the burden lies with the state"). {¶ 15} After Ross filed his appellate brief the Supreme Court of Ohio rejected the Tenth District's analysis in Smith, supra , and reversed the judgments in Mohammad and Mobarak, supra. See State v. Shalash , 148 Ohio St.3d 611 , 2016-Ohio-8358 , 71 N.E.3d 1089 .

11
State v. Ballewgreen
ohio · 1996 · cited in 1 Ohio opinions naming this issue, 2012–2012
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (17)

CaseCitedYears
State v. Long green
ohio · 1978
2 sentences

2020Courts are to notice plain error under Crim.R. 52(B) " 'with the utmost caution, under exceptional circumstances and only to prevent a manifest miscarriage of No. 19AP-425 6 justice.' " Barnes at 27 , quoting State v. Long, 53 Ohio St.2d 91 (1978), paragraph three of syllabus. {¶ 15} In the present case, appellant does not argue the existence of plain error on appeal.

2020The decision to correct a plain error is discretionary and should be made “with the utmost caution, under exceptional circumstances and only to prevent a manifest miscarriage of justice.” State v. Long, 53 Ohio St.2d 91 , 372 N.E.2d 804 (1978), paragraph three of the syllabus. {¶24} In the context of proving the existence of plain error, Durham must fulfill the requirements of the Supreme Court of Ohio described in State v. Brinkley, 105 Ohio St.3d 231 , 2005-Ohio-1507 , 824 N.E.2d 959 , ¶ 135 (2005) to prove prosecutorial misconduct.

81994–2020
Goldfuss v. Davidson green
ohio · 1997
2 sentences

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

22021–2023
City of Cleveland v. Scott green
ohioctapp · 1983
2 sentences

2012Masters assumed the existence of plain error despite acknowledging that “there are insufficient facts in the record for this court to [find whether offenses are allied] in the instant case.” Id.

2011Masters assumed the existence of plain error despite acknowledging that “there are insufficient facts in the record for this court to [find whether offenses are allied] in the instant case.” Id.

22011–2012
State v. Quarterman (Slip Opinion) green
ohio · 2014
2 sentences

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

2023Ohio Power Co. v. Burns, Slip Opinion No. 2022-Ohio-4713, ¶ 40 (arguments not presented to the trial court before it resolves the issue presented for review are forfeited for appellate review, except if the appellant can demonstrate the existence of plain error), citing State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 15 , and Goldfuss v. Davidson, 79 Ohio St.3d 116, 121-122 , 679 N.E.2d 1099 (1997); see also Tye v. Beausay, 2020-Ohio-3746 , 156 N.E.3d 331, ¶ 77 (2d Dist.), quoting USA Freight, L.L.C. v. CBS Outdoor Group, Inc., 2d Dist.

12023–2023
Rodger v. McDonald's Restaurants of Ohio, Inc. green
ohioctapp · 1982
2 sentences

2023Montgomery No. 26425, 2015-Ohio-1474 , ¶ 21, and Rodger v. McDonald’s Restaurants of Ohio, Inc., 8 Ohio App.3d 256, 258 , 456 N.E.2d 1262 (8th Dist.1982), fn. 7.

2023Montgomery No. 26425, 2015-Ohio-1474 , ¶ 21, and Rodger v. McDonald’s Restaurants of Ohio, Inc., 8 Ohio App.3d 256, 258 , 456 N.E.2d 1262 (8th Dist.1982), fn. 7.

12023–2023
State v. Waddell green
ohio · 1996
2 sentences

2022State v. Waddell, 75 Ohio St.3d 163, 166 , 661 N.E.2d 1043 (1996). {¶36} In the instant case, appellant does not explain why the outcome of the trial would have been different if the accomplice-testimony instruction would had been given.

2022State v. Waddell, 75 Ohio St.3d 163, 166 , 661 N.E.2d 1043 (1996). {¶36} In the instant case, appellant does not explain why the outcome of the trial would have been different if the accomplice-testimony instruction would had been given.

12022–2022
Casares v. Mercy St. Vincent Med. Ctr. neutral
ohioctapp · 2016
1 sentence

2020Id. at 124 . {¶ 34} Appellant was not prejudiced because the trial court’s decision to deny appellant’s challenge of Juror 9 for “good cause” did not force appellant to exhaust his peremptory challenges since he still had two more available to him prior to seating the jury.

12020–2020
State v. Brinkley green
ohio · 2005
1 sentence

2020The decision to correct a plain error is discretionary and should be made “with the utmost caution, under exceptional circumstances and only to prevent a manifest miscarriage of justice.” State v. Long, 53 Ohio St.2d 91 , 372 N.E.2d 804 (1978), paragraph three of the syllabus. {¶24} In the context of proving the existence of plain error, Durham must fulfill the requirements of the Supreme Court of Ohio described in State v. Brinkley, 105 Ohio St.3d 231 , 2005-Ohio-1507 , 824 N.E.2d 959 , ¶ 135 (2005) to prove prosecutorial misconduct.

12020–2020
Strickland v. Washington green
scotus · 1984
2 sentences

2017As a result, any error in the guilty verdicts for Counts 3 and 4 was harmless beyond a reasonable doubt. {¶65} In any event, in light of the overwhelming evidence of appellant’s guilt, he failed to demonstrate the existence of plain error. {¶66} For his third assigned error, appellant alleges: {¶67} “The defendant-appellant’s constitutional rights to due process and fair trial under the Fifth, Sixth and Fourteenth Amendments to the United States Constitution and Article I, Sections 10 and 16 of the Ohio Constitution were prejudiced by the ineffective assistance of counsel.” {¶68} The Ohio Supr

2017In order to demonstrate prejudice, the defendant must show “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would be different.” Strickland, supra, at 694 . {¶69} Moreover, “‘a court need not determine whether counsel’s performance was deficient before examining the prejudice suffered by the defendant as a result of the alleged deficiencies. * * * If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice, * * * that course should be followed.’“ Bradley, supra, at 143 , quoting Strickla

12017–2017
State v. Shalash green
ohioctapp · 2015
2 sentences

2017In Shalash , the Supreme Court of Ohio accepted a certified conflict between the Tenth District's holdings in Mohammad and Mobarak , which held that the sale or possession of controlled substance analogs were not criminalized until December 20, 2012 by H.B. 334, and the Twelfth District's holding in State v. Shalash , 2015-Ohio-3836 , 41 N.E.3d 1263 (12th Dist.), which held that they were criminalized as of October 17, 2011 by 2011 Sub.H.B.

2017In Shalash , the Supreme Court of Ohio accepted a certified conflict between the Tenth District's holdings in Mohammad and Mobarak , which held that the sale or possession of controlled substance analogs were not criminalized until December 20, 2012 by H.B. 334, and the Twelfth District's holding in State v. Shalash , 2015-Ohio-3836 , 41 N.E.3d 1263 (12th Dist.), which held that they were criminalized as of October 17, 2011 by 2011 Sub.H.B.

12017–2017
State v. Powell green
ohio · 1990
1 sentence

2017In fact, when the trial court explained why it did not believe the lesser included offense instructions were warranted under Counts 3 and 4, defense counsel said he agreed. {¶60} Crim.R. 30(A) provides in relevant part: “On appeal, a party may not assign as error the giving or the failure to give any instructions unless the party objects before the jury retires to consider its verdict, stating specifically the matter objected to and the grounds of the objection.” Thus, having waived any error related to the trial court’s decision not to give this instruction, our review is precluded unless app

12017–2017
State v. Bradley green
ohio · 1989
2 sentences

2017As a result, any error in the guilty verdicts for Counts 3 and 4 was harmless beyond a reasonable doubt. {¶65} In any event, in light of the overwhelming evidence of appellant’s guilt, he failed to demonstrate the existence of plain error. {¶66} For his third assigned error, appellant alleges: {¶67} “The defendant-appellant’s constitutional rights to due process and fair trial under the Fifth, Sixth and Fourteenth Amendments to the United States Constitution and Article I, Sections 10 and 16 of the Ohio Constitution were prejudiced by the ineffective assistance of counsel.” {¶68} The Ohio Supr

2017In order to demonstrate prejudice, the defendant must show “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would be different.” Strickland, supra, at 694 . {¶69} Moreover, “‘a court need not determine whether counsel’s performance was deficient before examining the prejudice suffered by the defendant as a result of the alleged deficiencies. * * * If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice, * * * that course should be followed.’“ Bradley, supra, at 143 , quoting Strickla

12017–2017
State v. Greene, 91104 (2-26-2009) neutral
ohioctapp · 2009
1 sentence

2013No. 91104, 2009-Ohio-850, ¶ 106 . {¶15} It is difficult to prove the existence of plain error in the court’s failure to give a jury instruction on the alibi.

12013–2013
State v. Shaw, 21880 (3-21-2008) green
ohioctapp · 2008
12009–2009
State v. Barnes green
ohio · 2002
12003–2003
State v. Moreland green
ohio · 1990
12001–2001
State v. Underwood green
ohio · 1983
11993–1993

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2913.02 (6) OH § Ohio Rev. Code § 2941.25 (5) OH § Ohio Rev. Code § 2929.14 (4) OH § Ohio Rev. Code § 2901.01 (3) OH § Ohio Rev. Code § 2903.11 (3) OH § Ohio Rev. Code § 2905.01 (3) OH § Ohio Rev. Code § 2907.01 (3) OH § Ohio Rev. Code § 2907.02 (3) OH § Ohio Rev. Code § 2953.08 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TN 159 (2000–2026) OH 33 (1993–2026) UT 30 (1993–2020) WI 12 (2007–2026) IL 11 (1978–2017) MO 10 (1990–2014) NC 7 (1986–2014) OR 7 (2010–2026) WY 5 (1991–2022) MI 4 (2003–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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