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26 Ohio opinions name it 2 courts 1988–2026 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 |
|---|---|---|
United States v. Harrisgreen2 sentences2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 | 1 | 4 |
Smith v. Illinoisgreen2 sentences1992The majority correctly recognizes that the Edwards test “prevents the police from wearing down and confusing the defendant.” Smith v. Illinois (1984), 469 U.S. 91, 98 , 105 S.Ct. 490, 494 , 83 L.Ed.2d 488, 495-496 . 1992The majority correctly recognizes that the Edwards test “prevents the police from wearing down and confusing the defendant.” Smith v. Illinois (1984), 469 U.S. 91, 98 , 105 S.Ct. 490, 494 , 83 L.Ed.2d 488, 495-496 . | 1 | 2 |
State v. Pategreen1 sentence2025“Absent evidence to the contrary, jurors are presumed to have obeyed the trial court’s instructions.” State v. Pate, 2020-Ohio-4190, ¶ 15 (11th Dist.), citing State v. Henderson, 39 Ohio St.3d 24, 33 (1988). {¶55} Thus, we conclude the trial court did not err in denying Edwards’ motion for severance since the evidence in this case would have been admissible as “other acts” evidence under Evid.R. 404(B)(2), and it was also simple and direct. | 1 | 1 |
State v. Hendersongreen1 sentence2025“Absent evidence to the contrary, jurors are presumed to have obeyed the trial court’s instructions.” State v. Pate, 2020-Ohio-4190, ¶ 15 (11th Dist.), citing State v. Henderson, 39 Ohio St.3d 24, 33 (1988). {¶55} Thus, we conclude the trial court did not err in denying Edwards’ motion for severance since the evidence in this case would have been admissible as “other acts” evidence under Evid.R. 404(B)(2), and it was also simple and direct. | 1 | 1 |
RNE Ents., L.L.C. v. Imperial Kitchen Cabinet Factory, L.L.C.green1 sentence2024See id. at 244 ; Villas at Pointe of Settlers Walk Condominium Assn. at ¶ 18 (in dispute between lienholders regarding the priority of liens, “the sale and distribution of funds has rendered the matter extinguished through satisfaction of the judgment, and like unpeeling the apple, this court cannot afford relief to the parties in the action”). {¶18} Next, as to Wilcox’s argument that the trial court wrongfully compelled sale of the property after having issued a stay, as set forth above, on July 7, 2023, the trial court granted a 30-day stay of the June 5, 2023 sheriff’s sale order based on i | 1 | 1 |
Montejo v. Louisianagreen2 sentences2022Accordingly, the trial court correctly determined that Taylor was able to knowingly and voluntarily waive his Fifth Amendment right to c0unsel. {¶ 27} But Miranda, Edwards, and Shatzer have only tangential application to the Sixth Amendment right to counsel analysis once an adversarial proceeding for a specific offense has commenced.4 See, e.g., Montejo v. Louisiana, 556 U.S. 778, 786 (2009). 2022Accordingly, the trial court correctly determined that Taylor was able to knowingly and voluntarily waive his Fifth Amendment right to c0unsel. {¶ 27} But Miranda, Edwards, and Shatzer have only tangential application to the Sixth Amendment right to counsel analysis once an adversarial proceeding for a specific offense has commenced.4 See, e.g., Montejo v. Louisiana, 556 U.S. 778, 786 (2009). | 1 | 1 |
Maryland v. Shatzergreen2 sentences2022Maryland v. Shatzer, 559 U.S. at 110 ("We think it appropriate to specify a period of time to avoid the consequence that continuation of the Edwards presumption 'will not reach the correct result most of the time.' It seems to us that period is 14 days. 2022Maryland v. Shatzer, 559 U.S. at 110 ("We think it appropriate to specify a period of time to avoid the consequence that continuation of the Edwards presumption 'will not reach the correct result most of the time.' It seems to us that period is 14 days. | 1 | 1 |
Edwards v. Arizonagreen2 sentences2011See Edwards, 451 U.S. at 486, fn. 9 (noting that “in the course of a meeting initiated by the accused, the conversation is not wholly one-sided, it is likely that the officers will say or do something that clearly would be ‘interrogation.’ In that event, the question would be whether a valid waiver of the right to counsel and the right to silence had occurred”). {¶41} As to the whether Johnson knowingly and voluntarily waived the right to counsel that he had previously invoked, we find that the evidence demonstrated a valid waiver of this right. 2011See Edwards, 451 U.S. at 486, fn. 9 (noting that “in the course of a meeting initiated by the accused, the conversation is not wholly one-sided, it is likely that the officers will say or do something that clearly would be ‘interrogation.’ In that event, the question would be whether a valid waiver of the right to counsel and the right to silence had occurred”). {¶41} As to the whether Johnson knowingly and voluntarily waived the right to counsel that he had previously invoked, we find that the evidence demonstrated a valid waiver of this right. | 1 | 1 |
State v. Bakergreen2 sentences2007See State v. Baker, 159 Ohio App.3d 462, 467-468 , 2005-Ohio-45 , 824 N.E.2d 162, ¶ 19 . 2007See State v. Baker, 159 Ohio App.3d 462, 467-468 , 2005-Ohio-45 , 824 N.E.2d 162, ¶ 19 . | 1 | 1 |
| Shoemaker v. Crawfordgreen | 1 | 1 |
Van DeRyt v. Van DeRytgreen2 sentences2007See Van DeRyt v. Van DeRyt (1966), 6 Ohio St.2d 31 , 36 (where the only issue is a mistake by the trial court in an otherwise effective judgment, the "reasons for the court's inherent power to vacate vanish"). 2007See Van DeRyt v. Van DeRyt (1966), 6 Ohio St.2d 31 , 36 (where the only issue is a mistake by the trial court in an otherwise effective judgment, the "reasons for the court's inherent power to vacate vanish"). | 1 | 1 |
| State v. Stahlgreen | 1 | 1 |
| State v. Campbellgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Henness
green
2 sentences2008"To invoke the right to counsel, a suspect must make a request with enough clarity that `a reasonable police officer in the circumstances would understand the statement to be a request for an attorney.'" Id., citing Davis , supra, at 459 . {¶ 12} As the United States Supreme Court explained, an unambiguous request for counsel under the Edwards rule provides law enforcement with a bright-line test to apply to interrogations, but permitting exclusion for something less than an unambiguous request leaves law enforcement uncertain and obviates the rule's "clarity and ease of application." Davis , 2008"To invoke the right to counsel, a suspect must make a request with enough clarity that `a reasonable police officer in the circumstances would understand the statement to be a request for an attorney.'" Id., citing Davis , supra, at 459 . {¶ 12} As the United States Supreme Court explained, an unambiguous request for counsel under the Edwards rule provides law enforcement with a bright-line test to apply to interrogations, but permitting exclusion for something less than an unambiguous request leaves law enforcement uncertain and obviates the rule's "clarity and ease of application." Davis , | 2 | 2008–2008 |
Colorado v. Connelly
green
2 sentences1999In applying the Edwards standard above, the Supreme Court of Ohio has stated that a confession is "involuntary and violative of the United States and Ohio Constitutions if it is the product of `coercive police activity."` State v. Loza (1994), 71 Ohio St.3d 61 , 66 , quoting Colorado v. Connelly (1986), 479 U.S. 157 , 167 . 1999In applying the Edwards standard above, the Supreme Court of Ohio has stated that a confession is "involuntary and violative of the United States and Ohio Constitutions if it is the product of `coercive police activity."` State v. Loza (1994), 71 Ohio St.3d 61 , 66 , quoting Colorado v. Connelly (1986), 479 U.S. 157 , 167 . | 2 | 1999–1999 |
State v. Loza
green
2 sentences1999In applying the Edwards standard above, the Supreme Court of Ohio has stated that a confession is "involuntary and violative of the United States and Ohio Constitutions if it is the product of `coercive police activity."` State v. Loza (1994), 71 Ohio St.3d 61 , 66 , quoting Colorado v. Connelly (1986), 479 U.S. 157 , 167 . 1999In applying the Edwards standard above, the Supreme Court of Ohio has stated that a confession is "involuntary and violative of the United States and Ohio Constitutions if it is the product of `coercive police activity."` State v. Loza (1994), 71 Ohio St.3d 61 , 66 , quoting Colorado v. Connelly (1986), 479 U.S. 157 , 167 . | 2 | 1999–1999 |
Oregon v. Bradshaw
green
2 sentences1991Oregon v. Bradshaw (1983), 462 U.S. 1039 , held that the Edwards rule was not violated when the accused reinitiated police interrogation if there was a subsequent knowing and intelligent waiver of counsel. 1991Oregon v. Bradshaw (1983), 462 U.S. 1039 , held that the Edwards rule was not violated when the accused reinitiated police interrogation if there was a subsequent knowing and intelligent waiver of counsel. | 2 | 1988–1991 |
State v. George
neutral
1 sentence2026Appellant also criticizes the fact that there was no testimony from the veterinarian, and no records submitted documenting the alleged injury. {¶19} Finally, appellant contends that the weight of the State’s evidence falls short of the statutory and case law standard for “cruelty.” In support of his contention, he relies on the holding of State v. George, 2023-Ohio-2016 (12th Dist.). | 1 | 2026–2026 |
State v. Burnside
green
1 sentence2022Motion to Suppress Standard of Review {¶ 18} "Appellate review of a ruling on a motion to suppress presents a mixed question of law and fact." State v. Turner, 163 Ohio St.3d 421 , 2020-Ohio-6773 , ¶ 14, citing State v. Burnside, 100 Ohio St.3d 152 , 2003-Ohio-5372 , ¶ 8. | 1 | 2022–2022 |
State v. Turner (Slip Opinion)
green
2 sentences2022Motion to Suppress Standard of Review {¶ 18} "Appellate review of a ruling on a motion to suppress presents a mixed question of law and fact." State v. Turner, 163 Ohio St.3d 421 , 2020-Ohio-6773 , ¶ 14, citing State v. Burnside, 100 Ohio St.3d 152 , 2003-Ohio-5372 , ¶ 8. 2022Motion to Suppress Standard of Review {¶ 18} "Appellate review of a ruling on a motion to suppress presents a mixed question of law and fact." State v. Turner, 163 Ohio St.3d 421 , 2020-Ohio-6773 , ¶ 14, citing State v. Burnside, 100 Ohio St.3d 152 , 2003-Ohio-5372 , ¶ 8. | 1 | 2022–2022 |
California v. Beheler
green
2 sentences2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 | 1 | 2020–2020 |
Minnesota v. Murphy
green
2 sentences2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 | 1 | 2020–2020 |
State v. Balo
green
2 sentences2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 | 1 | 2020–2020 |
State v. Fry
green
2 sentences2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 2020United States v. Harris (S.D.Ohio 1997), 961 F.Supp. 1127 , 1135; Minnesota v. Murphy (1984), 465 U.S. 420 , 424, * * * at fn. 3; State v. Fry (1988), 61 Ohio App.3d 689 * * *; State v. Meyers (Sept. 28, 2001), Allen App. No. 1–10–48, [ 2011-Ohio-3341 ]. {¶80} “In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but ‘the ultimate inquiry is simply whether there [was] a “formal arrest or restraint on freedom of movement” of the degree associated with a formal arrest.’ California v. Beheler (1983), 463 U.S. 1121 , 1125 | 1 | 2020–2020 |
State v. Clark
green
2 sentences2018State v. Clark, 119 Ohio St.3d 239 , 2008-Ohio-3748 , 893 N.E.2d 462, ¶ 30 . 2018State v. Clark, 119 Ohio St.3d 239 , 2008-Ohio-3748 , 893 N.E.2d 462, ¶ 30 . | 1 | 2018–2018 |
State ex rel. Edwards v. Toledo City School District Board of Education
green
1 sentence2018Bd. of Educ., 72 Ohio St.3d 106, 110 , 647 N.E.2d 799 (1995) (“[I]t is axiomatic that courts of appeals lack original jurisdiction over declaratory judgment actions. * * * Since Edwards’s claim for declaratory judgment is so obviously inappropriate * * * the court of appeals’ sua sponte dismissal of the complaint is affirmed as to that claim.”) {¶ 14} Here, while Albrecht’s petition is captioned in the form of a habeas corpus proceeding, he includes claims for equitable estoppel, duress, fraud, misrepresentation, and violations of his civil rights, due process, and separation of powers. | 1 | 2018–2018 |
Strickland v. Washington
green
2 sentences2009Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 ; State v. Bradley (1989), 42 Ohio St.3d 136 . {¶ 13} Edwards' claim of ineffective assistance of counsel is premised on his belief that the offenses to which he pled guilty were allied offenses of similar import. {¶ 14} R.C. 2941.25 sets forth the criteria for determining whether offenses are allied offenses of similar import. 2009Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 ; State v. Bradley (1989), 42 Ohio St.3d 136 . {¶ 13} Edwards' claim of ineffective assistance of counsel is premised on his belief that the offenses to which he pled guilty were allied offenses of similar import. {¶ 14} R.C. 2941.25 sets forth the criteria for determining whether offenses are allied offenses of similar import. | 1 | 2009–2009 |
State v. Bradley
green
1 sentence2009Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 ; State v. Bradley (1989), 42 Ohio St.3d 136 . {¶ 13} Edwards' claim of ineffective assistance of counsel is premised on his belief that the offenses to which he pled guilty were allied offenses of similar import. {¶ 14} R.C. 2941.25 sets forth the criteria for determining whether offenses are allied offenses of similar import. | 1 | 2009–2009 |
State v. Jackson
green
2 sentences2008As a result, if a defendant's request for an attorney is ambiguous or equivocal, so "that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," law enforcement need not cease questioning to "clarify whether the suspect actually invoked his right to counsel." (Emphasis sic.) Williams , supra, at ¶ 44 , citing Davis , supra, at 459 ; Curtis , supra, at ¶ 13 , citing Davis , supra, at 461-462 , and State v. Jackson , 107 Ohio St.3d 300 , 2006-Ohio-1 , at ¶ 93 . {¶ 13} Here, the vast majority of the interaction betwe 2008As a result, if a defendant's request for an attorney is ambiguous or equivocal, so "that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," law enforcement need not cease questioning to "clarify whether the suspect actually invoked his right to counsel." (Emphasis sic.) Williams , supra, at ¶ 44 , citing Davis , supra, at 459 ; Curtis , supra, at ¶ 13 , citing Davis , supra, at 461-462 , and State v. Jackson , 107 Ohio St.3d 300 , 2006-Ohio-1 , at ¶ 93 . {¶ 13} Here, the vast majority of the interaction betwe | 1 | 2008–2008 |
Davis v. United States
green
2 sentences2008"To invoke the right to counsel, a suspect must make a request with enough clarity that `a reasonable police officer in the circumstances would understand the statement to be a request for an attorney.'" Id., citing Davis , supra, at 459 . {¶ 12} As the United States Supreme Court explained, an unambiguous request for counsel under the Edwards rule provides law enforcement with a bright-line test to apply to interrogations, but permitting exclusion for something less than an unambiguous request leaves law enforcement uncertain and obviates the rule's "clarity and ease of application." Davis , 2008"To invoke the right to counsel, a suspect must make a request with enough clarity that `a reasonable police officer in the circumstances would understand the statement to be a request for an attorney.'" Id., citing Davis , supra, at 459 . {¶ 12} As the United States Supreme Court explained, an unambiguous request for counsel under the Edwards rule provides law enforcement with a bright-line test to apply to interrogations, but permitting exclusion for something less than an unambiguous request leaves law enforcement uncertain and obviates the rule's "clarity and ease of application." Davis , | 1 | 2008–2008 |
State v. Henness
green
2 sentences2008Voss argues on appeal that these statements harmed her case because they were inconsistent with her alibi defense. {¶ 69} In State v. Henness , 79 Ohio St.3d 53 , 1997-Ohio-405 , the court found that a suspect's statement that "I think I need an attorney," was not an unequivocal request for an attorney and therefore did not implicate the Edwards rule. 2008Voss argues on appeal that these statements harmed her case because they were inconsistent with her alibi defense. {¶ 69} In State v. Henness , 79 Ohio St.3d 53 , 1997-Ohio-405 , the court found that a suspect's statement that "I think I need an attorney," was not an unequivocal request for an attorney and therefore did not implicate the Edwards rule. | 1 | 2008–2008 |
State v. Williams, Unpublished Decision (12-30-2003)
green
2 sentences2008As a result, if a defendant's request for an attorney is ambiguous or equivocal, so "that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," law enforcement need not cease questioning to "clarify whether the suspect actually invoked his right to counsel." (Emphasis sic.) Williams , supra, at ¶ 44 , citing Davis , supra, at 459 ; Curtis , supra, at ¶ 13 , citing Davis , supra, at 461-462 , and State v. Jackson , 107 Ohio St.3d 300 , 2006-Ohio-1 , at ¶ 93 . {¶ 13} Here, the vast majority of the interaction betwe 2008As a result, if a defendant's request for an attorney is ambiguous or equivocal, so "that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," law enforcement need not cease questioning to "clarify whether the suspect actually invoked his right to counsel." (Emphasis sic.) Williams , supra, at ¶ 44 , citing Davis , supra, at 459 ; Curtis , supra, at ¶ 13 , citing Davis , supra, at 461-462 , and State v. Jackson , 107 Ohio St.3d 300 , 2006-Ohio-1 , at ¶ 93 . {¶ 13} Here, the vast majority of the interaction betwe | 1 | 2008–2008 |
State v. Curtis, Unpublished Decision (8-15-2006)
green
2 sentences2008As a result, if a defendant's request for an attorney is ambiguous or equivocal, so "that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," law enforcement need not cease questioning to "clarify whether the suspect actually invoked his right to counsel." (Emphasis sic.) Williams , supra, at ¶ 44 , citing Davis , supra, at 459 ; Curtis , supra, at ¶ 13 , citing Davis , supra, at 461-462 , and State v. Jackson , 107 Ohio St.3d 300 , 2006-Ohio-1 , at ¶ 93 . {¶ 13} Here, the vast majority of the interaction betwe 2008As a result, if a defendant's request for an attorney is ambiguous or equivocal, so "that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," law enforcement need not cease questioning to "clarify whether the suspect actually invoked his right to counsel." (Emphasis sic.) Williams , supra, at ¶ 44 , citing Davis , supra, at 459 ; Curtis , supra, at ¶ 13 , citing Davis , supra, at 461-462 , and State v. Jackson , 107 Ohio St.3d 300 , 2006-Ohio-1 , at ¶ 93 . {¶ 13} Here, the vast majority of the interaction betwe | 1 | 2008–2008 |
| Crawford v. Washington green | 1 | 2006–2006 |
| State v. Otte green | 1 | 2006–2006 |
| State v. Otte green | 1 | 2006–2006 |
| State v. Klapka, Unpublished Decision (6-4-2004) green | 1 | 2005–2005 |
| Albernaz v. United States green | 1 | 2002–2002 |
| Arizona v. Roberson green | 1 | 1991–1991 |
| State v. Van Hook green | 1 | 1991–1991 |
| Wyrick v. Fields green | 1 | 1988–1988 |
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.