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17 Ohio opinions name it 1 courts 2001–2025 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 |
|---|---|---|
Woods v. Telbgreen2 sentences2005Post-Release Control {¶ 21} The Ohio Supreme Court, in Woods v. Telb (2000), 89 Ohio St.3d 504 , held that the trial court must inform a defendant that post-release control is part of his/her sentence, either at sentencing or at the time of the plea hearing. 2004The Ohio supreme Court, in Woods v. Telb (2000), 89 Ohio St.3d 504 , held that the trial court must inform a defendant that post-release control is part of his/her sentence, either at sentencing or at the time of the plea hearing. | 1 | 6 |
State v. Veneygreen2 sentences2021Id., citing Crim.R. 11(C)(2)(c). “[S]trict compliance with Crim.R. 11(C)(2)(c) is required because constitutional rights are involved.” Id. {¶9} Appellant first argues that memory issues pertaining to the shooting, as well as her diagnosis of “bipolar disorder, PTSD, anxiety, and depression” raise “concerns about [her] state at the time of the plea hearing.” While Appellant’s argument is couched as a Crim.R. 11 compliance issue, her allegations also appear to implicate her competence to understand the plea. 2021Id., citing Crim.R. 11(C)(2)(c). “[S]trict compliance with Crim.R. 11(C)(2)(c) is required because constitutional rights are involved.” Id. {¶9} Appellant first argues that memory issues pertaining to the shooting, as well as her diagnosis of “bipolar disorder, PTSD, anxiety, and depression” raise “concerns about [her] state at the time of the plea hearing.” While Appellant’s argument is couched as a Crim.R. 11 compliance issue, her allegations also appear to implicate her competence to understand the plea. | 1 | 2 |
State v. Malornigreen1 sentence2025Id. (“[t]here is nothing in the record indicating that Dangler would not have entered his plea had he been more thoroughly informed of the details of the sex-offender-classification scheme”); State v. Hill, 2024-Ohio-2402, ¶ 29 (3d Dist.) (“Hill did not indicate at the change-of-plea hearing that he was pleading guilty based on the possibility of judicial 7 Case No. 2024-T-0088 release”); compare Malorni, 2024-Ohio-1122, at ¶ 20 (11th Dist.) (“it is evident on the face of the record that Malorni relied on these inaccurate oral advisements when entering her plea”). {¶17} Scott argues that, at t | 1 | 1 |
State v. Dangler (Slip Opinion)green1 sentence2025Id. (“[t]here is nothing in the record indicating that Dangler would not have entered his plea had he been more thoroughly informed of the details of the sex-offender-classification scheme”); State v. Hill, 2024-Ohio-2402, ¶ 29 (3d Dist.) (“Hill did not indicate at the change-of-plea hearing that he was pleading guilty based on the possibility of judicial 7 Case No. 2024-T-0088 release”); compare Malorni, 2024-Ohio-1122, at ¶ 20 (11th Dist.) (“it is evident on the face of the record that Malorni relied on these inaccurate oral advisements when entering her plea”). {¶17} Scott argues that, at t | 1 | 1 |
State v. Hillgreen1 sentence2025Id. (“[t]here is nothing in the record indicating that Dangler would not have entered his plea had he been more thoroughly informed of the details of the sex-offender-classification scheme”); State v. Hill, 2024-Ohio-2402, ¶ 29 (3d Dist.) (“Hill did not indicate at the change-of-plea hearing that he was pleading guilty based on the possibility of judicial 7 Case No. 2024-T-0088 release”); compare Malorni, 2024-Ohio-1122, at ¶ 20 (11th Dist.) (“it is evident on the face of the record that Malorni relied on these inaccurate oral advisements when entering her plea”). {¶17} Scott argues that, at t | 1 | 1 |
United States v. Marvin J. Damongreen1 sentence2021She argues that she was not sufficiently aware of the consequences of her plea because of “cognitive and mental health issues.” Specifically, she alleges that she had difficulty remembering the shooting, and she suffers from “bipolar disorder, PTSD, anxiety, and depression” that raise “concerns about [her] mental state at the time of the plea hearing.” Appellant also alleges that because the trial court was aware that she was taking psychotropic drugs while in jail, it had an obligation to conduct further inquiry into her mental state before accepting her plea under United States v. Damon, 191 | 1 | 1 |
Strickland v. Washingtongreen2 sentences2014Strickland v. Washington, 466 U.S. 668, 687-688, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984); State v. Bradley, 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶30} Despite Sanchez’s statements to the contrary, his trial counsel advocated for the withdrawal of his guilty plea. 2014Strickland v. Washington, 466 U.S. 668, 687-688, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984); State v. Bradley, 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶30} Despite Sanchez’s statements to the contrary, his trial counsel advocated for the withdrawal of his guilty plea. | 1 | 1 |
State v. Humphrey, Unpublished Decision (3-31-2006)green1 sentence2014Williams No. WM-05-012, 2006-Ohio-1630, ¶ 34 (“even though appellant notes that the trial court and appellant’s counsel recognized his mental state at the time of the plea hearing and at the sentencing hearing, the trial court’s decision to deny appellant’s motion [to withdraw his guilty plea] was not an abuse of discretion”); State v. Walker, 8th Dist. | 1 | 1 |
Woods v. Telbgreen1 sentence2004See Woods v. Telb, 89 Ohio St.3d 504 , 2000-Ohio-171 , ¶ 2 . | 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. Swift
green
2 sentences2014Cuyahoga No. 65794, 1994 WL 530892 , *2 (Sept. 29, 1994) (“A defendant may be mentally unstable and still be capable of understanding the charges against him and entering a plea in a knowing, intelligent, and voluntary manner”); State v. Swift, 86 Ohio App.3d 407, 411-412 , 621 N.E.2d 513 (11th Dist.1993) (defendant suffering from depression was mentally competent to enter guilty plea). {¶42} The record here is replete with evidence that supports the trial court’s determination that Leonhart’s mental infirmities did not prevent him from entering a valid Washington App. No. 13CA38 17 guilty ple 2006R.C. 2945.37 (G); State v. Swift (1993), 86 Ohio App.3d 407 , 411 . `A defendant may be emotionally disturbed or even psychotic and still be capable of understanding the charges against him and of assisting his counsel.' State v. Bock (1986), 28 Ohio St.3d 108 , 110." {¶ 34} Thus, even though appellant notes that the trial court and appellant's counsel recognized his mental state at the time of the plea hearing and at the sentencing hearing, the trial court's decision to deny appellant's motion was not an abuse of discretion. | 2 | 2006–2014 |
Hill v. Lockhart
green
2 sentences2023In the context of a guilty plea, this means that the defendant must show “‘that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty[.]’” State v. Xie, 62 Ohio St.3d 521, 524 , 584 N.E.2d 715 (1992), quoting Hill v. Lockhart, 474 U.S. 52, 59 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985). {¶ 12} Here, appellant argues that his trial counsel was ineffective for failing to provide him with an opportunity to review the state’s discovery containing the video surveillance evidence cited by the state at the time of the plea hearing. 2023In the context of a guilty plea, this means that the defendant must show “‘that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty[.]’” State v. Xie, 62 Ohio St.3d 521, 524 , 584 N.E.2d 715 (1992), quoting Hill v. Lockhart, 474 U.S. 52, 59 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985). {¶ 12} Here, appellant argues that his trial counsel was ineffective for failing to provide him with an opportunity to review the state’s discovery containing the video surveillance evidence cited by the state at the time of the plea hearing. | 1 | 2023–2023 |
State v. Xie
green
2 sentences2023In the context of a guilty plea, this means that the defendant must show “‘that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty[.]’” State v. Xie, 62 Ohio St.3d 521, 524 , 584 N.E.2d 715 (1992), quoting Hill v. Lockhart, 474 U.S. 52, 59 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985). {¶ 12} Here, appellant argues that his trial counsel was ineffective for failing to provide him with an opportunity to review the state’s discovery containing the video surveillance evidence cited by the state at the time of the plea hearing. 2023In the context of a guilty plea, this means that the defendant must show “‘that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty[.]’” State v. Xie, 62 Ohio St.3d 521, 524 , 584 N.E.2d 715 (1992), quoting Hill v. Lockhart, 474 U.S. 52, 59 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985). {¶ 12} Here, appellant argues that his trial counsel was ineffective for failing to provide him with an opportunity to review the state’s discovery containing the video surveillance evidence cited by the state at the time of the plea hearing. | 1 | 2023–2023 |
State v. Engle
green
1 sentence2020Failure on any of those points renders enforcement of the plea unconstitutional under both the United States Constitution and the Ohio Constitution.” State v. Engle, 74 Ohio St.3d 525, 527 , 1996-Ohio-179 , 660 N.E.2d 450 ; see also State v. Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621, ¶ 7 . | 1 | 2020–2020 |
State v. Engle
green
2 sentences2020Failure on any of those points renders enforcement of the plea unconstitutional under both the United States Constitution and the Ohio Constitution.” State v. Engle, 74 Ohio St.3d 525, 527 , 1996-Ohio-179 , 660 N.E.2d 450 ; see also State v. Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621, ¶ 7 . 2020Failure on any of those points renders enforcement of the plea unconstitutional under both the United States Constitution and the Ohio Constitution.” State v. Engle, 74 Ohio St.3d 525, 527 , 1996-Ohio-179 , 660 N.E.2d 450 ; see also State v. Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621, ¶ 7 . | 1 | 2020–2020 |
State v. Filiaggi
green
2 sentences2019Jefferson No. 17 JE 0007, 2018- Ohio-2774, ¶ 27, citing State v. Filiaggi, 86 Ohio St.3d 230, 236 , 714 N.E.2d 867 (1999); Case No. 18 CO 0030 –9– R.C. 2945.37(G). “[A] defendant’s plea is not void solely because he may be taking medication.” Kopras at ¶ 27, citing R.C. 2945.37(F). {¶15} In a Sixth District case, the trial court and the defendant discussed the psychotropic medications that the defendant was taking at the time of the plea hearing. 2019Jefferson No. 17 JE 0007, 2018- Ohio-2774, ¶ 27, citing State v. Filiaggi, 86 Ohio St.3d 230, 236 , 714 N.E.2d 867 (1999); Case No. 18 CO 0030 –9– R.C. 2945.37(G). “[A] defendant’s plea is not void solely because he may be taking medication.” Kopras at ¶ 27, citing R.C. 2945.37(F). {¶15} In a Sixth District case, the trial court and the defendant discussed the psychotropic medications that the defendant was taking at the time of the plea hearing. | 1 | 2019–2019 |
State v. Davis
green
1 sentence2018Richland No. 15CA6, 2015-Ohio-5196, ¶ 19 , quoting State v. Davison, 5th Dist. | 1 | 2018–2018 |
State v. Bradley
green
2 sentences2014Strickland v. Washington, 466 U.S. 668, 687-688, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984); State v. Bradley, 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶30} Despite Sanchez’s statements to the contrary, his trial counsel advocated for the withdrawal of his guilty plea. 2014Strickland v. Washington, 466 U.S. 668, 687-688, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984); State v. Bradley, 42 Ohio St.3d 136 , 538 N.E.2d 373 (1989), paragraphs two and three of the syllabus. {¶30} Despite Sanchez’s statements to the contrary, his trial counsel advocated for the withdrawal of his guilty plea. | 1 | 2014–2014 |
State v. Schaim
green
1 sentence2014“Once a court grants an evidentiary hearing to determine the degree of the defendant’s disability, it is within the trial court’s discretion to 12 decide whether the defendant requires assistance to understand the proceedings and the best means to accomplish that goal.” Id. at 65 . {¶ 15} Initially, we note that no objection was made at the time of the plea hearing. | 1 | 2014–2014 |
State v. Nero
green
2 sentences2012The requirement is met by “substantial compliance,” which means that, under the totality of the circumstances, the defendant “subjectively understands the implications of his plea * * * .” State v. Nero, 56 Ohio St.3d 106, 108 , 564 N.E.2d 474 (1990). {¶14} The prosecutor stated that Jennings would enter a guilty plea to Count 4 as a felony of the second degree that carried a potential prison term of “two to four years.” At the time of the plea hearing, however, second-degree felonies carried a potential mandatory prison sentence of two to eight years. 2012The requirement is met by “substantial compliance,” which means that, under the totality of the circumstances, the defendant “subjectively understands the implications of his plea * * * .” State v. Nero, 56 Ohio St.3d 106, 108 , 564 N.E.2d 474 (1990). {¶14} The prosecutor stated that Jennings would enter a guilty plea to Count 4 as a felony of the second degree that carried a potential prison term of “two to four years.” At the time of the plea hearing, however, second-degree felonies carried a potential mandatory prison sentence of two to eight years. | 1 | 2012–2012 |
State v. Bock
green
2 sentences2006R.C. 2945.37 (G); State v. Swift (1993), 86 Ohio App.3d 407 , 411 . `A defendant may be emotionally disturbed or even psychotic and still be capable of understanding the charges against him and of assisting his counsel.' State v. Bock (1986), 28 Ohio St.3d 108 , 110." {¶ 34} Thus, even though appellant notes that the trial court and appellant's counsel recognized his mental state at the time of the plea hearing and at the sentencing hearing, the trial court's decision to deny appellant's motion was not an abuse of discretion. 2006R.C. 2945.37 (G); State v. Swift (1993), 86 Ohio App.3d 407 , 411 . `A defendant may be emotionally disturbed or even psychotic and still be capable of understanding the charges against him and of assisting his counsel.' State v. Bock (1986), 28 Ohio St.3d 108 , 110." {¶ 34} Thus, even though appellant notes that the trial court and appellant's counsel recognized his mental state at the time of the plea hearing and at the sentencing hearing, the trial court's decision to deny appellant's motion was not an abuse of discretion. | 1 | 2006–2006 |
McDonald v. Keiter
neutral
2 sentences2001Painter, J., concurs separately. 1 (2000), 89 Ohio St.3d 504 , 733 N.E.2d 1103 , paragraph two of the syllabus ("Pursuant to R.C. 2967.28 (B) and (C), a trial court must inform the defendant at sentencing or at the time of the plea hearing that post-release control is part of the defendant's sentence."). 2 Tomkalski v. Maxwell (1963), 175 Ohio St. 377 , 378 , 194 N.E.2d 845 , 846 . 3 (Apr. 15, 1999), Marion App. No. 9-98-62, unreported. 4 Petrowski v. Ohio (June 30, 1999), Lake App. No. 98-L-057, unreported (emphasis added). 5 See, e.g ., Pewitt v. Lorain Correctional Inst . (1992), 64 Ohio St 2001Painter, J., concurs separately. 1 (2000), 89 Ohio St.3d 504 , 733 N.E.2d 1103 , paragraph two of the syllabus ("Pursuant to R.C. 2967.28 (B) and (C), a trial court must inform the defendant at sentencing or at the time of the plea hearing that post-release control is part of the defendant's sentence."). 2 Tomkalski v. Maxwell (1963), 175 Ohio St. 377 , 378 , 194 N.E.2d 845 , 846 . 3 (Apr. 15, 1999), Marion App. No. 9-98-62, unreported. 4 Petrowski v. Ohio (June 30, 1999), Lake App. No. 98-L-057, unreported (emphasis added). 5 See, e.g ., Pewitt v. Lorain Correctional Inst . (1992), 64 Ohio St | 1 | 2001–2001 |
Lippert v. Engle
green
2 sentences2001Painter, J., concurs separately. 1 (2000), 89 Ohio St.3d 504 , 733 N.E.2d 1103 , paragraph two of the syllabus ("Pursuant to R.C. 2967.28 (B) and (C), a trial court must inform the defendant at sentencing or at the time of the plea hearing that post-release control is part of the defendant's sentence."). 2 Tomkalski v. Maxwell (1963), 175 Ohio St. 377 , 378 , 194 N.E.2d 845 , 846 . 3 (Apr. 15, 1999), Marion App. No. 9-98-62, unreported. 4 Petrowski v. Ohio (June 30, 1999), Lake App. No. 98-L-057, unreported (emphasis added). 5 See, e.g ., Pewitt v. Lorain Correctional Inst . (1992), 64 Ohio St 2001Painter, J., concurs separately. 1 (2000), 89 Ohio St.3d 504 , 733 N.E.2d 1103 , paragraph two of the syllabus ("Pursuant to R.C. 2967.28 (B) and (C), a trial court must inform the defendant at sentencing or at the time of the plea hearing that post-release control is part of the defendant's sentence."). 2 Tomkalski v. Maxwell (1963), 175 Ohio St. 377 , 378 , 194 N.E.2d 845 , 846 . 3 (Apr. 15, 1999), Marion App. No. 9-98-62, unreported. 4 Petrowski v. Ohio (June 30, 1999), Lake App. No. 98-L-057, unreported (emphasis added). 5 See, e.g ., Pewitt v. Lorain Correctional Inst . (1992), 64 Ohio St | 1 | 2001–2001 |
Pewitt v. Superintendent, Lorain Correctional Institution
green
2 sentences2001Painter, J., concurs separately. 1 (2000), 89 Ohio St.3d 504 , 733 N.E.2d 1103 , paragraph two of the syllabus ("Pursuant to R.C. 2967.28 (B) and (C), a trial court must inform the defendant at sentencing or at the time of the plea hearing that post-release control is part of the defendant's sentence."). 2 Tomkalski v. Maxwell (1963), 175 Ohio St. 377 , 378 , 194 N.E.2d 845 , 846 . 3 (Apr. 15, 1999), Marion App. No. 9-98-62, unreported. 4 Petrowski v. Ohio (June 30, 1999), Lake App. No. 98-L-057, unreported (emphasis added). 5 See, e.g ., Pewitt v. Lorain Correctional Inst . (1992), 64 Ohio St 2001Painter, J., concurs separately. 1 (2000), 89 Ohio St.3d 504 , 733 N.E.2d 1103 , paragraph two of the syllabus ("Pursuant to R.C. 2967.28 (B) and (C), a trial court must inform the defendant at sentencing or at the time of the plea hearing that post-release control is part of the defendant's sentence."). 2 Tomkalski v. Maxwell (1963), 175 Ohio St. 377 , 378 , 194 N.E.2d 845 , 846 . 3 (Apr. 15, 1999), Marion App. No. 9-98-62, unreported. 4 Petrowski v. Ohio (June 30, 1999), Lake App. No. 98-L-057, unreported (emphasis added). 5 See, e.g ., Pewitt v. Lorain Correctional Inst . (1992), 64 Ohio St | 1 | 2001–2001 |
State ex rel. Pirman v. Money
green
2 sentences2001Pirman v. Money (1994), 69 Ohio St.3d 591 , 592 , 635 N.E.2d 26 , 29 . 8 Page v. Green (1963), 174 Ohio St. 178 , 179 , 187 N.E.2d 592 , 593 . 2001Pirman v. Money (1994), 69 Ohio St.3d 591 , 592 , 635 N.E.2d 26 , 29 . 8 Page v. Green (1963), 174 Ohio St. 178 , 179 , 187 N.E.2d 592 , 593 . | 1 | 2001–2001 |
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.