20 Ohio opinions name it 2 courts 2000–2025 3 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 |
|---|---|---|
City of Brecksville v. Cookgreen1 sentence2025Ohio’s speedy-trial statute, R.C. 2945.71, et seq., “was implemented to incorporate the constitutional protection of the right to a speedy trial.” Brecksville v. Cook, 75 Ohio St.3d 53, 55 (1996). | 1 | 1 |
State v. Hannahgreen1 sentence2015Richland No. 15-CA-1, 2015-Ohio-4438, ¶ 13 (noting Adams presumption); State v. Smith, 6th Dist. | 1 | 1 |
State v. Reed, 08ap-20 (11-20-2008)green1 sentence2015Franklin No. 08AP-20, 2008-Ohio-6082, ¶ 64 (applying Adams presumption); State v. Harold, 11th Dist. | 1 | 1 |
State v. Luckgreen2 sentences2015Compare Luck, 15 Ohio St.3d at 157-158 , 472 N.E.2d 1097 (when defendant claimed that killing was in self-defense, the absence of a witness who saw the killing and could have corroborated the claim was prejudicial). {¶ 104} Next, Adams alleges that some records of the 1986 grand-jury proceedings against him, including witness testimony, have been lost. 2015Compare Luck, 15 Ohio St.3d at 157-158 , 472 N.E.2d 1097 (when defendant claimed that killing was in self-defense, the absence of a witness who saw the killing and could have corroborated the claim was prejudicial). {¶ 104} Next, Adams alleges that some records of the 1986 grand-jury proceedings against him, including witness testimony, have been lost. | 1 | 1 |
State v. Bellgreen2 sentences2014“Where the defendant does not present an alibi defense, where he concedes being alone with the victims of the alleged sex offenses at various times throughout the relevant time frame, and where his defense is that the alleged touchings never happened, the inexactitude of dates or times in the indictment is not prejudicial error.” Barnecut at paragraph one of the syllabus; see also State v. Mundy, 99 Ohio App.3d 275, 297 , 650 N.E.2d 502 (2d Dist.1994) (the State’s failure to provide specific dates for 14 counts of gross sexual imposition regarding three children over extended period of time wa 2014“Where the defendant does not present an alibi defense, where he concedes being alone with the victims of the alleged sex offenses at various times throughout the relevant time frame, and where his defense is that the alleged touchings never happened, the inexactitude of dates or times in the indictment is not prejudicial error.” Barnecut at paragraph one of the syllabus; see also State v. Mundy, 99 Ohio App.3d 275, 297 , 650 N.E.2d 502 (2d Dist.1994) (the State’s failure to provide specific dates for 14 counts of gross sexual imposition regarding three children over extended period of time wa | 1 | 1 |
State v. Mundygreen2 sentences2014“Where the defendant does not present an alibi defense, where he concedes being alone with the victims of the alleged sex offenses at various times throughout the relevant time frame, and where his defense is that the alleged touchings never happened, the inexactitude of dates or times in the indictment is not prejudicial error.” Barnecut at paragraph one of the syllabus; see also State v. Mundy, 99 Ohio App.3d 275, 297 , 650 N.E.2d 502 (2d Dist.1994) (the State’s failure to provide specific dates for 14 counts of gross sexual imposition regarding three children over extended period of time wa 2014“Where the defendant does not present an alibi defense, where he concedes being alone with the victims of the alleged sex offenses at various times throughout the relevant time frame, and where his defense is that the alleged touchings never happened, the inexactitude of dates or times in the indictment is not prejudicial error.” Barnecut at paragraph one of the syllabus; see also State v. Mundy, 99 Ohio App.3d 275, 297 , 650 N.E.2d 502 (2d Dist.1994) (the State’s failure to provide specific dates for 14 counts of gross sexual imposition regarding three children over extended period of time wa | 1 | 1 |
State v. Bradleygreen2 sentences2004Accord State v. Bradley (1989), 42 Ohio St.3d 136 , 538 N.E.2d 373 . {¶ 31} We conclude, however, that Adams’s claim of ineffective assistance of counsel lacks merit. 2004Accord State v. Bradley (1989), 42 Ohio St.3d 136 , 538 N.E.2d 373 . {¶ 31} We conclude, however, that Adams’s claim of ineffective assistance of counsel lacks merit. | 1 | 1 |
State v. Hesslergreen2 sentences2004See State v. Hessler (2000), 90 Ohio St.3d 108, 115-116 , 734 N.E.2d 1237 (on juror misconduct, “we show deference to the trial judge, who sees and hears the events and thus is in a better position to accurately evaluate the situation and determine the appropriate scope of inquiry”). {¶ 44} Second, no misconduct by an actual juror occurred in this case. 2004See State v. Hessler (2000), 90 Ohio St.3d 108, 115-116 , 734 N.E.2d 1237 (on juror misconduct, “we show deference to the trial judge, who sees and hears the events and thus is in a better position to accurately evaluate the situation and determine the appropriate scope of inquiry”). {¶ 44} Second, no misconduct by an actual juror occurred in this case. | 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. Baker
green
2 sentences2017State v. Adams, 43 Ohio St.3d 67 (1989).7 {¶32} The trial court calculated Appellant’s time as follows, 7 Specifically, the trial court held, “Because I am satisfied, though, that the 270-day- speedy-trial period has not run in this case even when I accord the defendant the benefit of the Adams rule noted in the paragraph above, I need not consider today whether the Baker rule- which would of course give the prosecution even more time within which to bring this case to trial- applies.” The trial court references State v. Baker, 78 Ohio St.3d 108 (1997), syllabus, holding “In issuing a subseque 2017State v. Adams, 43 Ohio St.3d 67 (1989).7 {¶32} The trial court calculated Appellant’s time as follows, 7 Specifically, the trial court held, “Because I am satisfied, though, that the 270-day- speedy-trial period has not run in this case even when I accord the defendant the benefit of the Adams rule noted in the paragraph above, I need not consider today whether the Baker rule- which would of course give the prosecution even more time within which to bring this case to trial- applies.” The trial court references State v. Baker, 78 Ohio St.3d 108 (1997), syllabus, holding “In issuing a subseque | 2 | 2000–2017 |
State v. Ziko
neutral
2 sentences2000State v. Ziko (1991), 71 Ohio App.3d 832 , 595 N.E.2d 1019 . 2000State v. Ziko (1991), 71 Ohio App.3d 832 , 595 N.E.2d 1019 . | 2 | 2000–2000 |
State v. Maurer
green
2 sentences2022“To determine whether the defendant was deprived of a fair trial, we must determine whether, absent the improper remark[ ], the jury would have found the appellant guilty beyond a reasonable doubt.“ State v. Maurer, 15 Ohio St.3d 239, 267 , 473 N.E.2d 768 (1984). {¶ 37} We find that the trial court did not abuse its discretion when it overruled Adams’s motion for mistrial. 2022“To determine whether the defendant was deprived of a fair trial, we must determine whether, absent the improper remark[ ], the jury would have found the appellant guilty beyond a reasonable doubt.“ State v. Maurer, 15 Ohio St.3d 239, 267 , 473 N.E.2d 768 (1984). {¶ 37} We find that the trial court did not abuse its discretion when it overruled Adams’s motion for mistrial. | 1 | 2022–2022 |
State v. Bost
green
2 sentences2021Adams, however, did not explain what evidence the deceased witness “might have offered,” and, moreover, the deceased witness had actually implicated Adams in the [Cite as State v. Bost, 2021-Ohio-2190 .] murder before he died; we stated that “[i]f anything, [the witness's] absence at trial was a benefit to Adams's defense.” Id. *** Jones's inability to articulate specifically what his mother's testimony would have been does not render his claim of prejudice fatally speculative. 2021Adams, however, did not explain what evidence the deceased witness “might have offered,” and, moreover, the deceased witness had actually implicated Adams in the [Cite as State v. Bost, 2021-Ohio-2190 .] murder before he died; we stated that “[i]f anything, [the witness's] absence at trial was a benefit to Adams's defense.” Id. *** Jones's inability to articulate specifically what his mother's testimony would have been does not render his claim of prejudice fatally speculative. | 1 | 2021–2021 |
State v. Adams
green
2 sentences2017State v. Adams, 43 Ohio St.3d 67 (1989).7 {¶32} The trial court calculated Appellant’s time as follows, 7 Specifically, the trial court held, “Because I am satisfied, though, that the 270-day- speedy-trial period has not run in this case even when I accord the defendant the benefit of the Adams rule noted in the paragraph above, I need not consider today whether the Baker rule- which would of course give the prosecution even more time within which to bring this case to trial- applies.” The trial court references State v. Baker, 78 Ohio St.3d 108 (1997), syllabus, holding “In issuing a subseque 2017State v. Adams, 43 Ohio St.3d 67 (1989).7 {¶32} The trial court calculated Appellant’s time as follows, 7 Specifically, the trial court held, “Because I am satisfied, though, that the 270-day- speedy-trial period has not run in this case even when I accord the defendant the benefit of the Adams rule noted in the paragraph above, I need not consider today whether the Baker rule- which would of course give the prosecution even more time within which to bring this case to trial- applies.” The trial court references State v. Baker, 78 Ohio St.3d 108 (1997), syllabus, holding “In issuing a subseque | 1 | 2017–2017 |
State v. Keeley
green
1 sentence2017But in State v. Keeley, 2013-Ohio-474 , 989 N.E.2d 80 , ¶ 7-8 (4th Dist.), we held that the doctrine of res judicata does not bar consideration of postconviction claims that were not raised in an appeal of right that was pending at the time the postconviction petition was filed. {¶27} In Black we upheld a trial court’s dismissal of a petition for postconviction relief without holding an evidentiary hearing based in part on res judicata although the petition was filed when a direct appeal was pending. | 1 | 2017–2017 |
State v. Simmons, Unpublished Decision (2-27-2006)
green
1 sentence2017Highland No. 05CA4, 2006-Ohio-953 , 2006 WL 496001 , at ¶ 52 (noting that an appellate court should not intrude on the trial court's domain, where the trial court did not consider an issue). {¶ 50} Accordingly, we conclude that the trial court erred in overruling Adams' motion to suppress, insofar as the motion related to Adams' contention that he was unlawfully detained after the first field sobriety tests. | 1 | 2017–2017 |
State v. Martin
green
2 sentences2016State v. Martin, 103 Ohio St.3d 385 , 2004-Ohio-5471 , 816 N.E.2d 227 , syllabus. 2016State v. Martin, 103 Ohio St.3d 385 , 2004-Ohio-5471 , 816 N.E.2d 227 , syllabus. | 1 | 2016–2016 |
State v. Ross
green
1 sentence2016The state cites State v. Ross, 2013-Ohio-3220 , 996 N.E.2d 1033 (9th Dist.); State v. Bennett, 9th Dist. | 1 | 2016–2016 |
State ex rel. Dix v. Angelotta
green
2 sentences2015Dix v. Angelotta, 18 Ohio St.3d 115, 116 , 480 N.E.2d 407 (1985), fn. 1. 6 Adams’s brief filed in this court states his date of arrest as October 3, 2007, while the state’s brief states the date of arrest as October 4, 2007. 2015Dix v. Angelotta, 18 Ohio St.3d 115, 116 , 480 N.E.2d 407 (1985), fn. 1. 6 Adams’s brief filed in this court states his date of arrest as October 3, 2007, while the state’s brief states the date of arrest as October 4, 2007. | 1 | 2015–2015 |
State v. Kemp
green
1 sentence2014Clark No. 2014-CA-32, 2014-Ohio-4607 . {¶ 3} We conclude that the trial court did not abuse its discretion in overruling Adams’s motion without conducting a hearing or issuing findings of fact and conclusions of law. | 1 | 2014–2014 |
State v. Luff
green
2 sentences2013No. 13493, 1993 WL 323539 , * 5 (a "fitting corollary" to the Adams rule "is that where the charges in the second indictment are identical to * * * the initial indictment, then it is not unfair to apply a defendant's waiver of his speedy trial rights in the initial indictment to the subsequent indictment"); State v. Luff, 85 Ohio App.3d 785 (6th Dist.1993) (distinguishing Adams because both indictments contained the same charges). {¶ 29} To this end, appellant argues that the time waiver he signed on February 2, 2011 as to the original indictment was not knowingly, voluntarily, and intelligent 2013No. 13493, 1993 WL 323539 , * 5 (a "fitting corollary" to the Adams rule "is that where the charges in the second indictment are identical to * * * the initial indictment, then it is not unfair to apply a defendant's waiver of his speedy trial rights in the initial indictment to the subsequent indictment"); State v. Luff, 85 Ohio App.3d 785 (6th Dist.1993) (distinguishing Adams because both indictments contained the same charges). {¶ 29} To this end, appellant argues that the time waiver he signed on February 2, 2011 as to the original indictment was not knowingly, voluntarily, and intelligent | 1 | 2013–2013 |
Litva v. Village of Richmond
green
2 sentences2010Although appellate review of summary judgments is de novo, "an appellate court must limit its review of a summary judgment to that which was on record before the trial court." Litva v. Richmond, 172 Ohio App.3d 349 , 2007-Ohio-3499 , 874 N.E.2d 1243, at ¶18 . 2010Although appellate review of summary judgments is de novo, "an appellate court must limit its review of a summary judgment to that which was on record before the trial court." Litva v. Richmond, 172 Ohio App.3d 349 , 2007-Ohio-3499 , 874 N.E.2d 1243, at ¶18 . | 1 | 2010–2010 |
Pratts v. Hurley
green
1 sentence2008In re J.J. , 111 Ohio St.3d 205 , 2006-Ohio-5484 , ¶ 10-15 ; Pratts v. Hurley , 102 Ohio St.3d 81 , 2004-Ohio-1980 , ¶ 10-12 . | 1 | 2008–2008 |
In re J.J.
green
1 sentence2008In re J.J. , 111 Ohio St.3d 205 , 2006-Ohio-5484 , ¶ 10-15 ; Pratts v. Hurley , 102 Ohio St.3d 81 , 2004-Ohio-1980 , ¶ 10-12 . | 1 | 2008–2008 |
State v. Edmonson
green
2 sentences2006The Maximum Prison Term {¶ 62} Quinones and Adams challenge R.C. 2929.14(C), which states that “the court imposing a sentence upon an offender for a felony may impose the longest prison term authorized for the offense pursuant to division (A) of this section only upon offenders who committed the worst forms of the offense, upon offenders who pose the greatest likelihood of committing future crimes, upon certain major drug offenders under division (D)(3) of this section, and upon certain repeat violent offenders in accordance with division (D)(2) of this section.” (Emphasis added.) {¶ 63} Altho 2006The Maximum Prison Term {¶ 62} Quinones and Adams challenge R.C. 2929.14(C), which states that “the court imposing a sentence upon an offender for a felony may impose the longest prison term authorized for the offense pursuant to division (A) of this section only upon offenders who committed the worst forms of the offense, upon offenders who pose the greatest likelihood of committing future crimes, upon certain major drug offenders under division (D)(3) of this section, and upon certain repeat violent offenders in accordance with division (D)(2) of this section.” (Emphasis added.) {¶ 63} Altho | 1 | 2006–2006 |
State v. Evans
green
2 sentences2006The Maximum Prison Term {¶ 62} Quinones and Adams challenge R.C. 2929.14(C), which states that “the court imposing a sentence upon an offender for a felony may impose the longest prison term authorized for the offense pursuant to division (A) of this section only upon offenders who committed the worst forms of the offense, upon offenders who pose the greatest likelihood of committing future crimes, upon certain major drug offenders under division (D)(3) of this section, and upon certain repeat violent offenders in accordance with division (D)(2) of this section.” (Emphasis added.) {¶ 63} Altho 2006The Maximum Prison Term {¶ 62} Quinones and Adams challenge R.C. 2929.14(C), which states that “the court imposing a sentence upon an offender for a felony may impose the longest prison term authorized for the offense pursuant to division (A) of this section only upon offenders who committed the worst forms of the offense, upon offenders who pose the greatest likelihood of committing future crimes, upon certain major drug offenders under division (D)(3) of this section, and upon certain repeat violent offenders in accordance with division (D)(2) of this section.” (Emphasis added.) {¶ 63} Altho | 1 | 2006–2006 |
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.