searching inquiry (Ohio) · Go Syfert
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searching inquiry in Ohio

16 Ohio opinions name it 2 courts 1980–2025 2 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.

Followed or applied (9)

CaseFollowedCited
Shirley P. Langevine v. District of Columbiagreen
cadc · 1997 · cited in 3 Ohio opinions naming this issue, 2001–2018
2 sentences

2018Industries, Inc. v. Dist. of Columbia, 200 F.3d 836, 840 (D.C.Cir.2000), citing Langevine v. Dist. of Columbia, 106 F.3d 1018, 1023 (D.C.Cir.1997). {¶ 15} Because appellant filed his motion for a new trial based on newly discovered evidence 20 years after the jury's verdict, he sought leave from the trial court to file a delayed motion.

2016Industries, Inc. v. Dist. of Cuyahoga County, Case No. 103857 21 Columbia, 200 F.3d 836, 840 (DC 2000), citing Langevine v. Dist. of Columbia, 106 F.3d 1018, 1023 (DC 1997). {¶62} Under App.R. 5(C), when the state seeks leave from the court of appeals to appeal an order or judgment of the trial court, its motion for leave must set forth the errors it claims occurred in the proceedings of the trial court.

23
Tri County Industries, Inc. v. District of Columbiagreen
cadc · 2000 · cited in 3 Ohio opinions naming this issue, 2001–2018
2 sentences

2018Industries, Inc. v. Dist. of Columbia, 200 F.3d 836, 840 (D.C.Cir.2000), citing Langevine v. Dist. of Columbia, 106 F.3d 1018, 1023 (D.C.Cir.1997). {¶ 15} Because appellant filed his motion for a new trial based on newly discovered evidence 20 years after the jury's verdict, he sought leave from the trial court to file a delayed motion.

2016Industries, Inc. v. Dist. of Cuyahoga County, Case No. 103857 21 Columbia, 200 F.3d 836, 840 (DC 2000), citing Langevine v. Dist. of Columbia, 106 F.3d 1018, 1023 (DC 1997). {¶62} Under App.R. 5(C), when the state seeks leave from the court of appeals to appeal an order or judgment of the trial court, its motion for leave must set forth the errors it claims occurred in the proceedings of the trial court.

23
State v. Luckettgreen
ohioctapp · 2001 · cited in 2 Ohio opinions naming this issue, 2016–2018
2 sentences

2018No. 08AP-371, 2008-Ohio-6518, ¶ 12 . " 'A more searching inquiry is required' if the new trial is granted than if denied * * * because of 'the concern that a judge's nullification of the jury's verdict may encroach on the jury's important fact-finding function.' " State v. Luckett, 144 Ohio App.3d 648, 655 (8th Dist.2001), quoting Tri Cty.

2016No. 08AP-371, 2008-Ohio-6518, ¶12 . “‘A more searching inquiry is required’ if the new trial is granted than if denied, * * * because of ‘the concern that a judge's nullification of the jury's verdict may encroach on the jury's important fact-finding function.’” State v. Luckett, 144 Ohio App.3d 648, 655, 761 (8th Dist. 2001), quoting Tri Cty.

22
Theodore W. Oswald v. Daniel Bertrandgreen
ca7 · 2004 · cited in 2 Ohio opinions naming this issue, 2005–2025
2 sentences

2025See Jackson at ¶ 58 , quoting Oswald v. Bertrand, 374 F.3d 475, 480 (7th Cir. 2004) (“The greater the probability of bias, ‘the more searching the inquiry needed to make reasonably sure that an unbiased jury is impaneled.’”).

2005The greater the probability of bias, “the more searching the inquiry needed to make reasonably sure that an unbiased jury is impaneled.” Oswald v. Bertrand, 374 F.3d at 480 . {¶ 59} At a minimum, the trial court should have granted defense counsel’s request to inform the venire that one murder victim was a three-year-old child.

12
Cleveland Bar Ass'n v. Jonesgreen
ohio · 1994 · cited in 2 Ohio opinions naming this issue, 2006–2009
2 sentences

2009Trinity’s complaint was narrowly limited, both in scope and time, which may not “require a searching inquiry into partnership affairs.” Id. at 308 , 631 N.E.2d 1040 .

2009Trinity’s complaint was narrowly limited, both in scope and time, which may not “require a searching inquiry into partnership affairs.” Id. at 308 , 631 N.E.2d 1040 .

12
State v. Bradleygreen
ohioctapp · 2017 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025"If an amendment changes the penalty or degree of the charged offense, it changes the identity of the offense and is not permitted by Crim.R. 7(D)." State v. Bradley, 2017-Ohio-7121, ¶ 19 (12th Dist.).

11
Wheeling Steel Corp. v. Porterfieldgreen
ohio · 1970 · cited in 1 Ohio opinions naming this issue, 2018–2018
2 sentences

2018See Wheeling Steel Corp. v. Porterfield , 24 Ohio St.2d 24 , 28-29, 263 N.E.2d 249 (1970) ("Neither the Board of Tax Appeals, nor this court, may legislate to add a requirement to a statute enacted by the General Assembly"). {¶ 21} Notwithstanding Sprout's ostensible compliance with R.C. 5713.03, Lowe's argues that a more searching inquiry into Sprout's appraisal shows that in substance he valued the property as if it were encumbered by a lease and that he relied on comparable sales of lease-encumbered properties only to inflate the subject property's value.

2018See Wheeling Steel Corp. v. Porterfield , 24 Ohio St.2d 24 , 28-29, 263 N.E.2d 249 (1970) ("Neither the Board of Tax Appeals, nor this court, may legislate to add a requirement to a statute enacted by the General Assembly"). {¶ 21} Notwithstanding Sprout's ostensible compliance with R.C. 5713.03, Lowe's argues that a more searching inquiry into Sprout's appraisal shows that in substance he valued the property as if it were encumbered by a lease and that he relied on comparable sales of lease-encumbered properties only to inflate the subject property's value.

11
State ex rel. Blair v. Balrajgreen
ohio · 1994 · cited in 1 Ohio opinions naming this issue, 2000–2000
1 sentence

2000As an example, the court said a formal accounting is “a pointless exercise * * * [in cases involving] disputes over a very limited time or number of transactions, whose resolution would not require a searching inquiry into partnership affairs.” Id. at 309, 631 N.E.2d at 1044.

11
Sorrells v. United Statesgreen
scotus · 1932 · cited in 1 Ohio opinions naming this issue, 1980–1980
1 sentence

1980See 287 U.S. [infra], at 451.” “***The predisposition and criminal design of the defendant are relevant* **and if the defendant seeks acquittal by reason of entrapment he cannot complain of an appropriate and searching inquiry into his own conduct and predisposition as bearing uppn that issue.***” Sorrells v. United States (1932), 287 U.S. 435, at 451 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
State v. Townsend, 08ap-371 (12-11-2008) green
ohioctapp · 2008
2 sentences

2018No. 08AP-371, 2008-Ohio-6518, ¶ 12 . " 'A more searching inquiry is required' if the new trial is granted than if denied * * * because of 'the concern that a judge's nullification of the jury's verdict may encroach on the jury's important fact-finding function.' " State v. Luckett, 144 Ohio App.3d 648, 655 (8th Dist.2001), quoting Tri Cty.

2016No. 08AP-371, 2008-Ohio-6518, ¶12 . “‘A more searching inquiry is required’ if the new trial is granted than if denied, * * * because of ‘the concern that a judge's nullification of the jury's verdict may encroach on the jury's important fact-finding function.’” State v. Luckett, 144 Ohio App.3d 648, 655, 761 (8th Dist. 2001), quoting Tri Cty.

22016–2018
Hanes v. Giambrone green
ohioctapp · 1984
2 sentences

1994Hanes v. Giambrone (1984), 14 Ohio App.3d 400 , 14 OBR 518, 471 N.E.2d 801 (allowing an action between partners to collect unpaid partnership contributions).

1994Hanes v. Giambrone (1984), 14 Ohio App.3d 400 , 14 OBR 518, 471 N.E.2d 801 (allowing an action between partners to collect unpaid partnership contributions).

21994–1994
State v. Stodgel green
ohioctapp · 2013
1 sentence

2025"On the other hand, an inquiry into whether the 'identity' of a crime has been changed requires a more searching analysis." Stodgel, 2013-Ohio-1109 .

12025–2025
Steak 'n Shake, Inc. v. Warren Cty. Bd. of Revision (Slip Opinion) green
ohio · 2015
2 sentences

2018In translating this assertion to a claim of legal error, Lowe's places principal reliance on a trilogy of decisions of this court: Steak 'N Shake , 145 Ohio St.3d 244 , 2015-Ohio-4836 , 48 N.E.3d 535 ; Rite Aid , 146 Ohio St.3d 173 , 2016-Ohio-371 , 54 N.E.3d 1177 ; and Lowe's , 145 Ohio St.3d 375 , 2016-Ohio-372 , 49 N.E.3d 1266 . {¶ 22} In Steak 'N Shake , we ruled that "[b]ecause the encumbrance of a lease may affect market value, sale prices of leased properties generally must be adjusted when determining the value of comparable unleased properties." Id. at ¶ 34-35 (intervening subheading)

2018In translating this assertion to a claim of legal error, Lowe's places principal reliance on a trilogy of decisions of this court: Steak 'N Shake , 145 Ohio St.3d 244 , 2015-Ohio-4836 , 48 N.E.3d 535 ; Rite Aid , 146 Ohio St.3d 173 , 2016-Ohio-371 , 54 N.E.3d 1177 ; and Lowe's , 145 Ohio St.3d 375 , 2016-Ohio-372 , 49 N.E.3d 1266 . {¶ 22} In Steak 'N Shake , we ruled that "[b]ecause the encumbrance of a lease may affect market value, sale prices of leased properties generally must be adjusted when determining the value of comparable unleased properties." Id. at ¶ 34-35 (intervening subheading)

12018–2018
Rite Aid of Ohio, Inc. v. Washington Cty. Bd. of Revision (Slip Opinion) green
ohio · 2016
2 sentences

2018In translating this assertion to a claim of legal error, Lowe's places principal reliance on a trilogy of decisions of this court: Steak 'N Shake , 145 Ohio St.3d 244 , 2015-Ohio-4836 , 48 N.E.3d 535 ; Rite Aid , 146 Ohio St.3d 173 , 2016-Ohio-371 , 54 N.E.3d 1177 ; and Lowe's , 145 Ohio St.3d 375 , 2016-Ohio-372 , 49 N.E.3d 1266 . {¶ 22} In Steak 'N Shake , we ruled that "[b]ecause the encumbrance of a lease may affect market value, sale prices of leased properties generally must be adjusted when determining the value of comparable unleased properties." Id. at ¶ 34-35 (intervening subheading)

2018In translating this assertion to a claim of legal error, Lowe's places principal reliance on a trilogy of decisions of this court: Steak 'N Shake , 145 Ohio St.3d 244 , 2015-Ohio-4836 , 48 N.E.3d 535 ; Rite Aid , 146 Ohio St.3d 173 , 2016-Ohio-371 , 54 N.E.3d 1177 ; and Lowe's , 145 Ohio St.3d 375 , 2016-Ohio-372 , 49 N.E.3d 1266 . {¶ 22} In Steak 'N Shake , we ruled that "[b]ecause the encumbrance of a lease may affect market value, sale prices of leased properties generally must be adjusted when determining the value of comparable unleased properties." Id. at ¶ 34-35 (intervening subheading)

12018–2018
Lowe's Home Ctrs., Inc. v. Washington Cty. Bd. of Revision (Slip Opinion) green
ohio · 2016
2 sentences

2018In translating this assertion to a claim of legal error, Lowe's places principal reliance on a trilogy of decisions of this court: Steak 'N Shake , 145 Ohio St.3d 244 , 2015-Ohio-4836 , 48 N.E.3d 535 ; Rite Aid , 146 Ohio St.3d 173 , 2016-Ohio-371 , 54 N.E.3d 1177 ; and Lowe's , 145 Ohio St.3d 375 , 2016-Ohio-372 , 49 N.E.3d 1266 . {¶ 22} In Steak 'N Shake , we ruled that "[b]ecause the encumbrance of a lease may affect market value, sale prices of leased properties generally must be adjusted when determining the value of comparable unleased properties." Id. at ¶ 34-35 (intervening subheading)

2018In translating this assertion to a claim of legal error, Lowe's places principal reliance on a trilogy of decisions of this court: Steak 'N Shake , 145 Ohio St.3d 244 , 2015-Ohio-4836 , 48 N.E.3d 535 ; Rite Aid , 146 Ohio St.3d 173 , 2016-Ohio-371 , 54 N.E.3d 1177 ; and Lowe's , 145 Ohio St.3d 375 , 2016-Ohio-372 , 49 N.E.3d 1266 . {¶ 22} In Steak 'N Shake , we ruled that "[b]ecause the encumbrance of a lease may affect market value, sale prices of leased properties generally must be adjusted when determining the value of comparable unleased properties." Id. at ¶ 34-35 (intervening subheading)

12018–2018
Strickland v. Washington green
scotus · 1984
1 sentence

2010Id. at 694 . {¶ 81} Defendant asserts that his counsel “told dubious anecdotes” during voir dire, rather than conducting a searching inquiry during this very serious case.

12010–2010
United States v. Ivan Melchor Moreno and Rigoberto Melchor Moreno green
ca5 · 1976
2 sentences

2009Id. at 1046-1049 . {¶ 36} As noted, an abuse-of-discretion standard applies to the granting or denial of the privilege against self incrimination.

2009No. 3924, 1986 WL 4343 , *1-2. {¶ 35} In United States v. Moreno (C.A.5, 1976), 536 F.2d 1042 , the court held that when a witness invokes the privilege against self-incrimination, the trial court cannot accept the witness’s claims at face value but must conduct a searching inquiry into the validity and extent of the witness’s claim with respect to each challenged question, and that a blanket refusal to answer will not lie.

12009–2009
Carl McNeal v. Hi-Lo Powered Scaffolding, Inc., an Ohio Corporation green
cadc · 1988
1 sentence

1993Thus, “a more searching inquiry is required to prevent the trial court from ‘encroaching on the jury’s important fact-finding function.’ ” McNeal v. Hi-Lo Powered Scaffolding, Inc. (C.A.D.C.1988), 836 F.2d 637, 646 , quoting Vander Zee v. Karabatsos (C.A.D.C.1978), 589 F.2d 723, 729 .

11993–1993
Rein J. Vander Zee v. Kimon T. Karabatsos green
cadc · 1979
1 sentence

1993Thus, “a more searching inquiry is required to prevent the trial court from ‘encroaching on the jury’s important fact-finding function.’ ” McNeal v. Hi-Lo Powered Scaffolding, Inc. (C.A.D.C.1988), 836 F.2d 637, 646 , quoting Vander Zee v. Karabatsos (C.A.D.C.1978), 589 F.2d 723, 729 .

11993–1993

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.11 (3)

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.

Where else courts name it

NY 172 (1896–2026) PA 68 (1944–2025) MI 60 (1972–2026) NJ 56 (1964–2026) CT 38 (1981–2024) GA 32 (1944–2024) CA 19 (1910–2026) DC 18 (1946–2018) MD 17 (1952–2026) OH 16 (1980–2025) FL 14 (1971–2020) WA 13 (1930–2016) MN 12 (1994–2026) TX 12 (1986–2026) RI 11 (1979–2015) MS 11 (1973–2026) WI 11 (1969–2020) IA 11 (1969–2019) IL 11 (1958–2018) HI 10 (1980–2023) MA 8 (1935–2017) AL 8 (1973–2023) UT 8 (2006–2025) MO 7 (1955–2017) DE 7 (1988–2022) KY 6 (1901–2025) MT 6 (1922–2024) OK 4 (1992–2013) KS 4 (1962–2019) NH 4 (1981–2012) AK 3 (1993–2017) IN 3 (1899–1982) VA 3 (2018–2020) ME 3 (1980–2002) VT 3 (1958–2012) CO 2 (1993–2020) WY 2 (2011–2018) WV 2 (1984–1996) AR 2 (1978–2016) AZ 2 (1975–1993) OR 2 (1991–2017)

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.

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