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20 Ohio opinions name it 2 courts 2012–2025 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.
| Case | Followed | Cited |
|---|---|---|
State v. Millergreen2 sentences2025“A trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has been imposed and (2) when the judgment contains a clerical error.” State v. Miller, 2010-Ohio-5705, ¶ 14 , citing State ex rel. 2025None of these three cases confer a trial court with authority to consider a post-judgment motion for clarification of a criminal sentence, and Armengau points to no other authority indicating the trial court could effectively reconsider its prior judgment through a so-called motion for clarification. {¶ 39} Instead, as the state notes, a “trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has been imposed and (2) when the judgment contains a clerical error.” State v. Miller, 2010-Ohio-5705, ¶ 14 , citing | 2 | 16 |
L. Bryan Carr Co., LPA v. LaForgegreen2 sentences2025Bryan Carr Co., LPA v. LaForge, 2025-Ohio-889, ¶ 10 (11th Dist.), quoting State ex rel. 2025Bryan Carr Co., LPA v. LaForge, 2025-Ohio-889, ¶ 10 (11th Dist.), citing State ex rel. | 2 | 2 |
State v. Carlislegreen2 sentences2018"Once a final judgment has been issued pursuant to Crim.R. 32, the trial court's jurisdiction ends." State v. Gilbert , 143 Ohio St.3d 150 , 2014-Ohio-4562 , 35 N.E.3d 493 , ¶ 9. " '[A]bsent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment.' " Id. at ¶ 8, quoting State v. Carlisle , 131 Ohio St.3d 127 , 2011-Ohio-6553 , 961 N.E.2d 671 , ¶ 1. {¶ 12} Consequently, "a trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has bee 2018"Once a final judgment has been issued pursuant to Crim.R. 32, the trial court's jurisdiction ends." State v. Gilbert , 143 Ohio St.3d 150 , 2014-Ohio-4562 , 35 N.E.3d 493 , ¶ 9. " '[A]bsent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment.' " Id. at ¶ 8, quoting State v. Carlisle , 131 Ohio St.3d 127 , 2011-Ohio-6553 , 961 N.E.2d 671 , ¶ 1. {¶ 12} Consequently, "a trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has bee | 1 | 2 |
State v. O'Nealgreen1 sentence2015See also O’Neal VI¸ 2012-Ohio-396, ¶ 4-6 (holding that Mr. O’Neal could not challenge the propriety of the trial court’s allied offense determinations as those issues were barred by res judicata since they could have been raised in an earlier appeal). | 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. Holling
green
2 sentences2025Cruzado v. Zaleski, 2006-Ohio-5795 , ¶ 19, quoting State v. Brown, 2000-Ohio-1660 (3rd Dist.). {¶32} “[A] trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has been imposed and (2) when the judgment contains a clerical error.” Miller at ¶ 14 ; In other words, the trial court has the authority to correct clerical errors in its own judgment entries. {¶33} This Court has recently held in State v. Holling, 2025-Ohio-385 (5th Dist. 2025), ¶ 30, “[c]lerical errors do not involve a legal decision or judgment; 2025State v. Holling, 2025-Ohio-385 (5th Dist.), ¶28; State v. Mitchell, 2020-Ohio-3417 (11th Dist.), ¶81. {¶29} In the case sub judice, the trial court does note an inaccuracy in the judgment entry denying the appellant’s petition for post-conviction relief. | 2 | 2025–2025 |
State v. Mitchell
green
2 sentences2025State v. Holling, 2025-Ohio-385 (5th Dist.), ¶28; State v. Mitchell, 2020-Ohio-3417 (11th Dist.), ¶81. {¶29} In the case sub judice, the trial court does note an inaccuracy in the judgment entry denying the appellant’s petition for post-conviction relief. 2021No. 2019-P-0105, 2020-Ohio-3417, ¶ 35 , citing State v. Miller, 127 Ohio St.3d 407 , 2010-Ohio-5705, ¶ 14 . {¶ 60} Here, the trial court issued a final judgment of conviction and sentence on March 3, 2020. | 2 | 2021–2025 |
State ex rel. Cruzado v. Zaleski
green
1 sentence2021Cruzado v. Zaleski, 111 Ohio St.3d 353 , 2006-Ohio- 5795, ¶ 19, citing Crim.R. 36. | 1 | 2021–2021 |
State v. Gilbert (Slip Opinion)
green
2 sentences2018"Once a final judgment has been issued pursuant to Crim.R. 32, the trial court's jurisdiction ends." State v. Gilbert , 143 Ohio St.3d 150 , 2014-Ohio-4562 , 35 N.E.3d 493 , ¶ 9. " '[A]bsent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment.' " Id. at ¶ 8, quoting State v. Carlisle , 131 Ohio St.3d 127 , 2011-Ohio-6553 , 961 N.E.2d 671 , ¶ 1. {¶ 12} Consequently, "a trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has bee 2018"Once a final judgment has been issued pursuant to Crim.R. 32, the trial court's jurisdiction ends." State v. Gilbert , 143 Ohio St.3d 150 , 2014-Ohio-4562 , 35 N.E.3d 493 , ¶ 9. " '[A]bsent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment.' " Id. at ¶ 8, quoting State v. Carlisle , 131 Ohio St.3d 127 , 2011-Ohio-6553 , 961 N.E.2d 671 , ¶ 1. {¶ 12} Consequently, "a trial court lacks the authority to reconsider its own valid, final judgment in a criminal case, with two exceptions: (1) when a void sentence has bee | 1 | 2018–2018 |
State v. Roehrig
neutral
1 sentence2016Defiance No. 4-15-15, 2015-Ohio-5187, ¶ 9 , citing State v. Miller, 127 Ohio St.3d 407 , 2010-Ohio-5705 , ¶ 14 and State v. Burton, 12th Dist. | 1 | 2016–2016 |
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.