18 Ohio opinions name it 2 courts 2004–2026 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State v. Frazier, Unpublished Decision (3-11-2004)green1 sentence2026As the court of appeals put it, “the fact-finder would have had a difficult time looking at the evidence in support of each offense as ‘simple and distinct because the temptation would be too great to respond to the evidence emotionally rather than rationally.’” 2024-Ohio-43 at ¶ 26 (5th Dist.), quoting State v. Frazier, 2004-Ohio-1121, ¶ 18 (8th Dist.). 18 January Term, 2026 {¶ 47} For these reasons, the Fifth District Court of Appeals correctly held that the trial court erred by denying Reed’s motion to sever, and I would therefore affirm its judgment. | 1 | 1 |
State v. Xiegreen1 sentence2025A. Law {¶18} Crim.R. 32.1 provides: “A motion to withdraw a plea of guilty or no contest may be made only before sentence is imposed; but to correct manifest injustice the court after sentence may set aside the judgment of conviction and permit the defendant Scioto App. No. 23CA4041 9 to withdraw his or her plea.” “ ‘While trial courts should ”freely and liberally” grant a presentence motion to withdraw a guilty plea, a defendant does not ”have an absolute right to withdraw a guilty plea prior to sentencing.” ’ ” State v. Estep, 2024-Ohio-58 , ¶ 16 (4th Dist.), quoting State v. Howard, 2017-Oh | 1 | 1 |
State v. Howardgreen1 sentence2025A. Law {¶18} Crim.R. 32.1 provides: “A motion to withdraw a plea of guilty or no contest may be made only before sentence is imposed; but to correct manifest injustice the court after sentence may set aside the judgment of conviction and permit the defendant Scioto App. No. 23CA4041 9 to withdraw his or her plea.” “ ‘While trial courts should ”freely and liberally” grant a presentence motion to withdraw a guilty plea, a defendant does not ”have an absolute right to withdraw a guilty plea prior to sentencing.” ’ ” State v. Estep, 2024-Ohio-58 , ¶ 16 (4th Dist.), quoting State v. Howard, 2017-Oh | 1 | 1 |
State v. Lilesgreen2 sentences2022Allen No. 1-18-69, 2019-Ohio-3029, ¶ 33 . 2022Accord Liles, 2019-Ohio-3029, at ¶ 34 . | 1 | 1 |
State v. Aleshiregreen1 sentence2022Licking No. 2011- CA-73, 2012-Ohio-16, ¶ 31 (stating that “the scope of the hearing upon a defendant’s motion to withdraw his or her previously entered negotiated guilty plea is within the trial court’s discretion”). {¶17} Here, although we are concerned by the trial court’s decision to permit the parties to address Reed’s motion to withdraw his guilty pleas after it had already ruled on his motion to withdraw, we cannot say that the scope of the hearing was unreasonable, arbitrary, or unconscionable. | 1 | 1 |
State v. Goodmangreen1 sentence2018Trumbull No. 2014-T-0047, 2014-Ohio-4884, ¶ 18 (despite R.C. 2947.23(C) giving 5 Reed was sentenced to prison on July 13, 2016, and he claims the garnishments on his prison account began in July 2017. 6 Reed claimed for the first time on appeal that he did not receive a copy of the trial court’s October 20, 2016 decision overruling his first motion for stay of court costs. | 1 | 1 |
State v. Evansgreen1 sentence2013The trial court erred by failing to grant Reed's motion to suppress any evidence that stemmed from his illegal detainment. {¶12} In reaching this conclusion, the Reed court at ¶ 10-11 quoted "a list of factors collected from various cases which may be considered by a court in determining whether an officer had reasonable suspicion to administer field sobriety tests under the totality of the circumstances" from State v. Evans, 127 Ohio App.3d 56, fn. 2 (11th Dist.1998): "(1) the time of day of the stop (Friday or Saturday night as opposed to, e.g., Tuesday morning); (2) the location of the stop | 1 | 1 |
Porter v. Saez, Unpublished Decision (5-4-2004)green2 sentences2004Bryant and Watson, JJ., concur. 1 In Porter , at ¶ 54, this court stated that "because Porter's first assignment of error only raises the issue of whether the trial court properly denied Porter's motion for partial summary judgment pertaining to Porter's claim of a fraudulent transfer and not whether the trial court erred when it granted Reed's motion for partial [sic] summary judgment pertaining to Porter's claim of a fraudulent transfer, we do not consider here whether the trial court erred in granting Reed's motion for partial [sic] summary judgment." Upon reconsideration, we find that we e 2004See defendant Reed's motion for summary judgment filed March 28, 2003; Porter , at ¶ 32. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Reed v. Triton Servs., Inc.
neutral
2 sentences2019In this case, we specifically found in Triton I that "Reed's claim was actually one for specific performance" and therefore the only remedy is "in equity alone." Reed I, 2014-Ohio-3185 at ¶ 23 . {¶ 41} The Shareholders attempt to distinguish the relevant case law by arguing that their legal defenses should be tried to a jury, including claims that Reed is barred by the doctrines of equitable estoppel and waiver. 2017Reed v. Triton Servs., Inc., 2014-Ohio-3185 , 15 N.E.3d 936 , ¶ 23, 37 (12th Dist.). {¶ 4} On remand, Judge Ferenc denied as untimely appellants’ motion for leave to file an amended answer and counterclaim (filed more than ten months after the case was remanded) and found that appellants had no right to a jury trial because Reed’s predominant claim for relief was equitable in nature. *699 {¶ 5} Appellants sought a writ of prohibition from the court of appeals to enjoin Judge Ferenc from conducting a trial in the underlying case without first granting them leave to amend their answer, vacating | 2 | 2017–2019 |
State v. Champion
green
2 sentences2024For the reasons previously stated, Reed’s claim that she -28- “may” have accidentally injured H.M. by falling on her on the porch was both implausible and unsupported even by Reed’s own testimony. {¶ 50} Furthermore, in a case decided after the self-defense statute was amended, the Supreme Court of Ohio stressed that: “For nearly 100 years, this court has held that self-defense ‘presumes intentional, willful use of force to repel force or escape force.” (Emphasis in original.) State v. Wilson, 2024-Ohio-776, ¶ 18 , quoting Champion, 109 Ohio St. at 286-287 . 2024The court interpreted this to mean “that the use of force must be intentional – not accidental.” Id. | 1 | 2024–2024 |
State v. Wilson
green
1 sentence2024For the reasons previously stated, Reed’s claim that she -28- “may” have accidentally injured H.M. by falling on her on the porch was both implausible and unsupported even by Reed’s own testimony. {¶ 50} Furthermore, in a case decided after the self-defense statute was amended, the Supreme Court of Ohio stressed that: “For nearly 100 years, this court has held that self-defense ‘presumes intentional, willful use of force to repel force or escape force.” (Emphasis in original.) State v. Wilson, 2024-Ohio-776, ¶ 18 , quoting Champion, 109 Ohio St. at 286-287 . | 1 | 2024–2024 |
State v. Bethel (Slip Opinion)
green
1 sentence2022Reed’s motion for leave to file a delayed motion for a new trial in light of State v. Bethel, __ Ohio St.3d __, 2022-Ohio-783 , __ N.E.3d __. | 1 | 2022–2022 |
State v. Dehass
green
1 sentence2020A finding of an error in law is a legitimate ground for reversal, but a difference of opinion on credibility of witnesses and evidence is not." See, also State v. DeHass (1967), 10 Ohio St.2d 230 , syllabus 1. {¶13} We accept the trial court's conclusion that Reed's violation of the traffic laws gave Officer Dodge reasonable suspicion to stop Reed's vehicle because the factual findings made by the trial court are supported by competent and credible evidence. | 1 | 2020–2020 |
State v. Holmes, L-08-1127 (12-19-2008)
green
1 sentence2020Lucas No. L-08-1127, 2008-Ohio-6804, ¶ 12 , and State v. Sutton, 6th Dist. | 1 | 2020–2020 |
State v. Reed
neutral
1 sentence2020The trial court denied Reed’s motion for jail-time credit, found that he had violated the terms of his community- control sanctions, and imposed a “definite sentence for the term of five (5) years.” Reed appealed to the Sixth District Court of Appeals. {¶ 8} The appellate court reversed, stating that as used in R.C. 2949.08(C)(1), the term “confinement” is “synonymous with the term ‘detention’ as defined in R.C. 2921.01(E).” 2019-Ohio-1266 , 133 N.E.3d 1068 , ¶ 11, citing State v. Holmes, 6th Dist. | 1 | 2020–2020 |
Grava v. Parkman Twp.
green
1 sentence2018Therefore, Reed’s petition for postconviction relief is untimely. {¶16} Even if Reed’s motion for postconviction relief was timely filed, or if one of the exceptions under R.C. 2953.23 applied, the doctrine of res judicata barred the trial court from considering his claims. {¶17} Under the doctrine of res judicata, “[a] valid, final judgment rendered upon the merits bars all subsequent actions based upon any claim arising out of the transaction or occurrence that was the subject matter of the previous action.” Grava v. Parkman Twp., 73 Ohio St.3d 379 , 1995-Ohio-331 , 653 N.E.2d 226 , syllabus | 1 | 2018–2018 |
State v. Reynolds
green
1 sentence2018The state, citing State v. Reynolds, 79 Ohio St.3d 158 , 1997-Ohio-304 , 679 N.E.2d 1131 , contended that this challenge is actually a petition for postconviction relief. {¶11} In Reynolds, the defendant, after his direct appeal, filed a motion to correct or vacate his sentence with the trial court, seeking to vacate his sentence for a gun specification because the state allegedly did not prove that the firearm used in the robbery was operable beyond a reasonable doubt. | 1 | 2018–2018 |
State v. Nero
green
2 sentences2018Nero, 56 Ohio St.3d 106, 108 , 564 N.E.2d 474 . 2018Nero, 56 Ohio St.3d 106, 108 , 564 N.E.2d 474 . | 1 | 2018–2018 |
State v. Reynolds
green
2 sentences2018The state, citing State v. Reynolds, 79 Ohio St.3d 158 , 1997-Ohio-304 , 679 N.E.2d 1131 , contended that this challenge is actually a petition for postconviction relief. {¶11} In Reynolds, the defendant, after his direct appeal, filed a motion to correct or vacate his sentence with the trial court, seeking to vacate his sentence for a gun specification because the state allegedly did not prove that the firearm used in the robbery was operable beyond a reasonable doubt. 2018The state, citing State v. Reynolds, 79 Ohio St.3d 158 , 1997-Ohio-304 , 679 N.E.2d 1131 , contended that this challenge is actually a petition for postconviction relief. {¶11} In Reynolds, the defendant, after his direct appeal, filed a motion to correct or vacate his sentence with the trial court, seeking to vacate his sentence for a gun specification because the state allegedly did not prove that the firearm used in the robbery was operable beyond a reasonable doubt. | 1 | 2018–2018 |
Grava v. Parkman Township
green
2 sentences2018Therefore, Reed’s petition for postconviction relief is untimely. {¶16} Even if Reed’s motion for postconviction relief was timely filed, or if one of the exceptions under R.C. 2953.23 applied, the doctrine of res judicata barred the trial court from considering his claims. {¶17} Under the doctrine of res judicata, “[a] valid, final judgment rendered upon the merits bars all subsequent actions based upon any claim arising out of the transaction or occurrence that was the subject matter of the previous action.” Grava v. Parkman Twp., 73 Ohio St.3d 379 , 1995-Ohio-331 , 653 N.E.2d 226 , syllabus 2018Therefore, Reed’s petition for postconviction relief is untimely. {¶16} Even if Reed’s motion for postconviction relief was timely filed, or if one of the exceptions under R.C. 2953.23 applied, the doctrine of res judicata barred the trial court from considering his claims. {¶17} Under the doctrine of res judicata, “[a] valid, final judgment rendered upon the merits bars all subsequent actions based upon any claim arising out of the transaction or occurrence that was the subject matter of the previous action.” Grava v. Parkman Twp., 73 Ohio St.3d 379 , 1995-Ohio-331 , 653 N.E.2d 226 , syllabus | 1 | 2018–2018 |
State v. Veney
green
2 sentences2018Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621 , at 14. 2018Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621 , at 14. | 1 | 2018–2018 |
State v. Jefferson
green
2 sentences2018Montgomery No. 26022, 2014-Ohio-2555, ¶ 21 . “‘[T]he merger of allied offenses of similar import occurs at sentencing.’” Id., quoting Jefferson at ¶ 21. {¶27} Likewise, after review of the totality of the circumstances surrounding Reed’s plea, we find that Reed subjectively understood the implications of his plea. 2018Montgomery No. 26022, 2014-Ohio-2555, ¶ 21 . “‘[T]he merger of allied offenses of similar import occurs at sentencing.’” Id., quoting Jefferson at ¶ 21. {¶27} Likewise, after review of the totality of the circumstances surrounding Reed’s plea, we find that Reed subjectively understood the implications of his plea. | 1 | 2018–2018 |
State v. Comen
green
1 sentence2016We disagree. {¶14} “A trial court has broad discretion to decide how to fashion jury instructions, but it must ‘fully and completely give the jury all instructions which are relevant and necessary for the jury to weigh the evidence and discharge its duty as the fact finder.’” State v. White, 142 Ohio St.3d 277 , 2015-Ohio-492 , ¶ 46, quoting State v. Comen, 50 Ohio St.3d 206 (1990), paragraph two of the syllabus. | 1 | 2016–2016 |
State v. White
green
1 sentence2016We disagree. {¶14} “A trial court has broad discretion to decide how to fashion jury instructions, but it must ‘fully and completely give the jury all instructions which are relevant and necessary for the jury to weigh the evidence and discharge its duty as the fact finder.’” State v. White, 142 Ohio St.3d 277 , 2015-Ohio-492 , ¶ 46, quoting State v. Comen, 50 Ohio St.3d 206 (1990), paragraph two of the syllabus. | 1 | 2016–2016 |
Little v. Corrections Corp.
green
1 sentence2010Id. {¶64} Appellants do not contest the objective component of Reed's claim, arguing that Reed failed to show that any of Appellants were subjectively aware of the risk of Howell's alleged sexual assaults against Reed. | 1 | 2010–2010 |
State v. Saxon
green
1 sentence2009The "sentencing package" doctrine is "a federal doctrine that requires [federal courts] to consider the sanctions imposed on multiple offenses as the components of a single, comprehensive sentencing plan." State v. Saxon , 109 Ohio St.3d 176 , 2006-Ohio-1245 , 846 N.E.2d 824 , ¶ 5. | 1 | 2009–2009 |
State ex rel. Miley v. Parrott
green
1 sentence2004Miley v. Parrott (1996), 77 Ohio St.3d 64 . | 1 | 2004–2004 |
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.