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27 Ohio opinions name it 2 courts 2002–2026 5 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.
| Case | Followed | Cited |
|---|---|---|
State v. Murphygreen2 sentences2026“The Court stated that a defendant can demonstrate a violation of his equal protection rights pursuant to the Fourteenth Amendment of the United States Constitution by showing that the State’s use of peremptory challenges at the defendant’s trial was used to intentionally exclude members of the defendant’s race.” State v. Evans, 2010-Ohio-4813, ¶ 6 (3d Dist.). {¶45} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the p 2026“The Court stated that a defendant can demonstrate a violation of his equal protection rights pursuant to the Fourteenth Amendment of the United States Constitution by showing that the State’s use of peremptory challenges at the defendant’s trial was used to intentionally exclude members of the defendant’s race.” State v. Evans, 2010-Ohio-4813, ¶ 6 (3d Dist.). {¶45} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the p | 5 | 6 |
Batson v. Kentuckygreen2 sentences2017No. 24668, 2010-Ohio-2573 , ¶ 33, citing Batson v. Kentucky, 476 U.S. 79, 89 (1986). “’A court adjudicates a Batson claim in three steps.’” State v. Were, 118 Ohio St.3d 448 , 2008-Ohio-2762 , ¶ 61, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “’First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination. 2010No. 24668, 2010-Ohio-2573 , 2010 WL 2298570 , at ¶ 33, citing Batson v. Kentucky (1986), 476 U.S. 79, 89 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 . “ ‘ “A court adjudicates a Batson claim in three steps.” ’ ” State v. Were, 118 Ohio St.3d 448 , 2008-Ohio-2762 , 890 N.E.2d 263 , at ¶ 61, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , 804 N.E.2d 433 , at ¶ 106, quoting State v. Murphy (2001), 91 Ohio St.3d 516, 528 , 747 N.E.2d 765 . “ ‘First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination. | 3 | 9 |
Johnson v. Californiagreen2 sentences2026“At the first step of the Batson inquiry, the defendant is not required to demonstrate that ‘the challenge was more likely than not the product of purposeful discrimination.’” Hawkins, 2018-Ohio-4649, at ¶ 9 (3d Dist.), quoting Johnson v. California, 545 U.S. 162, 170-173 (2005). “‘Instead, a defendant satisfies the requirements of Batson’s first step by producing evidence sufficient to permit the trial judge to draw an inference that discrimination has occurred.’” Id., quoting Johnson at 170 . {¶46} “‘Second, if the trial court finds [a prima facie case of discrimination], the proponent of th 2026“At the first step of the Batson inquiry, the defendant is not required to demonstrate that ‘the challenge was more likely than not the product of purposeful discrimination.’” Hawkins, 2018-Ohio-4649, at ¶ 9 (3d Dist.), quoting Johnson v. California, 545 U.S. 162, 170-173 (2005). “‘Instead, a defendant satisfies the requirements of Batson’s first step by producing evidence sufficient to permit the trial judge to draw an inference that discrimination has occurred.’” Id., quoting Johnson at 170 . {¶46} “‘Second, if the trial court finds [a prima facie case of discrimination], the proponent of th | 1 | 3 |
State v. Hawkinsgreen2 sentences2026“At the first step of the Batson inquiry, the defendant is not required to demonstrate that ‘the challenge was more likely than not the product of purposeful discrimination.’” Hawkins, 2018-Ohio-4649, at ¶ 9 (3d Dist.), quoting Johnson v. California, 545 U.S. 162, 170-173 (2005). “‘Instead, a defendant satisfies the requirements of Batson’s first step by producing evidence sufficient to permit the trial judge to draw an inference that discrimination has occurred.’” Id., quoting Johnson at 170 . {¶46} “‘Second, if the trial court finds [a prima facie case of discrimination], the proponent of th 2024“At the first step of the Batson inquiry, the defendant is not required to demonstrate that ‘the challenge was more likely than not the product of purposeful discrimination.’” Hawkins, 2018-Ohio-4649, at ¶ 9 , quoting Johnson v. California, 545 U.S. 162 , 170- 173, 125 S.Ct. 2410 (2005). “‘Instead, a defendant satisfies the requirements of Batson’s first step by producing evidence sufficient to permit the trial judge to draw an inference that discrimination has occurred.’” Id., quoting Johnson at 170 . {¶70} “‘Second, if the trial court finds [a prima facie case of discrimination], the propone | 1 | 2 |
State v. Evansgreen2 sentences2026“The Court stated that a defendant can demonstrate a violation of his equal protection rights pursuant to the Fourteenth Amendment of the United States Constitution by showing that the State’s use of peremptory challenges at the defendant’s trial was used to intentionally exclude members of the defendant’s race.” State v. Evans, 2010-Ohio-4813, ¶ 6 (3d Dist.). {¶45} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the p 2018Allen No. 1-10-22, 2010-Ohio-4813, ¶ 6 , citing Batson at 96. {¶9} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination.’” Id., quoting Bryan at ¶ 106, citing Batson at 96-98 . | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Bryan
green
2 sentences2025“First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination.” State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , 804 N.E.2d 433 , ¶ 106. 2024Allen No. 1-10-22, 2010- Ohio-4813, ¶ 6. -37- Case Nos. 1-23-17, 1-23-18 and 1-23-19 {¶69} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination.’” Id., quoting Bryan at ¶ 106. | 16 | 2010–2025 |
Purkett v. Elem
green
2 sentences2024Id. at ¶ 51. “‘[U]nless a discriminatory intent is inherent in the prosecutor’s explanation, the reason offered will be deemed -6- Case No. 1-23-02 race neutral.” Id., quoting Purkett v. Elem, 514 U.S. 765, 768 , 115 S.Ct. 1769 , 131 L.Ed.2d 834 (1995). {¶10} At the third step, the trial court must decide, based on all of the circumstances, whether the opponent of the peremptory challenge has established purposeful racial discrimination. 2024Id. at ¶ 51. “‘[U]nless a discriminatory intent is inherent in the prosecutor’s explanation, the reason offered will be deemed -6- Case No. 1-23-02 race neutral.” Id., quoting Purkett v. Elem, 514 U.S. 765, 768 , 115 S.Ct. 1769 , 131 L.Ed.2d 834 (1995). {¶10} At the third step, the trial court must decide, based on all of the circumstances, whether the opponent of the peremptory challenge has established purposeful racial discrimination. | 2 | 2009–2024 |
State v. Frazier
green
2 sentences2024Allen No. 1-10-22, 2010- Ohio-4813, ¶ 6. -37- Case Nos. 1-23-17, 1-23-18 and 1-23-19 {¶69} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination.’” Id., quoting Bryan at ¶ 106. 2018Allen No. 1-10-22, 2010-Ohio-4813, ¶ 6 , citing Batson at 96. {¶9} “‘“A court adjudicates a Batson claim in three steps.”’” State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohio-5048 , ¶ 64, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “‘First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination.’” Id., quoting Bryan at ¶ 106, citing Batson at 96-98 . | 2 | 2018–2024 |
State v. Were
green
2 sentences2017No. 24668, 2010-Ohio-2573 , ¶ 33, citing Batson v. Kentucky, 476 U.S. 79, 89 (1986). “’A court adjudicates a Batson claim in three steps.’” State v. Were, 118 Ohio St.3d 448 , 2008-Ohio-2762 , ¶ 61, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , ¶ 106, quoting State v. Murphy, 91 Ohio St.3d 516, 528 (2001). “’First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination. 2010No. 24668, 2010-Ohio-2573 , 2010 WL 2298570 , at ¶ 33, citing Batson v. Kentucky (1986), 476 U.S. 79, 89 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 . “ ‘ “A court adjudicates a Batson claim in three steps.” ’ ” State v. Were, 118 Ohio St.3d 448 , 2008-Ohio-2762 , 890 N.E.2d 263 , at ¶ 61, quoting State v. Bryan, 101 Ohio St.3d 272 , 2004-Ohio-971 , 804 N.E.2d 433 , at ¶ 106, quoting State v. Murphy (2001), 91 Ohio St.3d 516, 528 , 747 N.E.2d 765 . “ ‘First, the opponent of the peremptory challenge must make a prima facie case of racial discrimination. | 2 | 2010–2017 |
Hernandez v. New York
green
2 sentences2014“At this step of the inquiry, the issue is the facial validity of the prosecutor’s explanation.” Hernandez v. New York, 500 U.S. 352, 360 , 111 S.Ct. 1859 , 114 L.Ed.2d 395 (1991). 2014“At this step of the inquiry, the issue is the facial validity of the prosecutor’s explanation.” Hernandez v. New York, 500 U.S. 352, 360 , 111 S.Ct. 1859 , 114 L.Ed.2d 395 (1991). | 2 | 2012–2014 |
State v. Johnson (Slip Opinion)
green
2 sentences2018Batson at 96 ; State v. Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903 , 45 N.E.3d 208, ¶ 20 . 2018Batson at 96 ; State v. Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903 , 45 N.E.3d 208, ¶ 20 . | 1 | 2018–2018 |
State v. Herring
green
2 sentences2012Batson at 96-98 ; State v. Herring (2002), 94 Ohio St.3d 246, 255-56 , 762 N.E.2d 940 . {¶78} When a trial court evaluates the attorney's explanation, "a court must determine whether, assuming the proffered reasons for the peremptory challenges are true, the challenges violate the Equal Protection Clause as a matter of law." Hernandez v. New York (1991), 500 U.S. 352, 359 , 111 S.Ct. 1859 , 114 L.Ed.2d 395 . 2012Batson at 96-98 ; State v. Herring (2002), 94 Ohio St.3d 246, 255-56 , 762 N.E.2d 940 . {¶78} When a trial court evaluates the attorney's explanation, "a court must determine whether, assuming the proffered reasons for the peremptory challenges are true, the challenges violate the Equal Protection Clause as a matter of law." Hernandez v. New York (1991), 500 U.S. 352, 359 , 111 S.Ct. 1859 , 114 L.Ed.2d 395 . | 1 | 2012–2012 |
State v. Hill
green
1 sentence2011“To make a prima facie case of such purposeful discrimination, an accused must demonstrate: (a) that members of a recognized racial group were peremptorily challenged; and (b) that the facts and any other relevant circumstances raise an inference that the prosecutor used the peremptory challenges to exclude jurors on account of their race.” (Internal citations and quotations omitted.) State v. Hill (1995), 73 Ohio St.3d 433, 444-445 . {¶8} “Second, if the trial court finds this requirement fulfilled, the proponent of the challenge must provide a racially neutral explanation for the challenge. | 1 | 2011–2011 |
State v. White
green
2 sentences2009See Batson; State v. White (1999), 85 Ohio St.3d 433, 436-438 , 709 N.E.2d 140, 147-149 . {¶ 26} Once a party raises a Batson issue, the court adjudicates the claim in three steps: first, the opponent of the peremptory challenge at issue must make a prima facie case that the proponent was engaging in racial discrimination; second, the proponent must come forward with a race-neutral explanation for the strike; and third, the trial court must decide, on the basis of all the circumstances, whether the opponent has proved racial discrimination. 2009See Batson; State v. White (1999), 85 Ohio St.3d 433, 436-438 , 709 N.E.2d 140, 147-149 . {¶ 26} Once a party raises a Batson issue, the court adjudicates the claim in three steps: first, the opponent of the peremptory challenge at issue must make a prima facie case that the proponent was engaging in racial discrimination; second, the proponent must come forward with a race-neutral explanation for the strike; and third, the trial court must decide, on the basis of all the circumstances, whether the opponent has proved racial discrimination. | 1 | 2009–2009 |
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.
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.