perceived error (Ohio) · Go Syfert
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perceived error in Ohio

15 Ohio opinions name it 2 courts 1989–2023 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 (5)

CaseFollowedCited
State ex rel. Nicholls v. Industrial Commissiongreen
ohio · 1998 · cited in 5 Ohio opinions naming this issue, 2001–2009
2 sentences

2001Comm. (1998), 81 Ohio St.3d 454 , 692 N.E.2d 188 , the commission’s explanation that the order “was issued in error” was not sufficient to justify continuing jurisdiction absent identification of the perceived error.

2001Comm. (1998), 81 Ohio St.3d 454 , 692 N.E.2d 188 , the commission’s explanation that the order “was issued in error” was not sufficient to justify continuing jurisdiction absent identification of the perceived error.

15
State v. Barnesgreen
ohio · 2002 · cited in 3 Ohio opinions naming this issue, 2003–2023
2 sentences

2023Since Farr failed to object in the trial court as to the perceived error, he has forfeited all but plain error on appeal. {¶19} For plain error to apply, the trial court must have deviated from a legal rule, the error must be plain, i.e., an obvious defect in the proceeding, and the error must have affected the defendant’s “substantial rights.” State v. Barnes, 94 Ohio St.3d 21, 27 (2002). “[T]o demonstrate that the trial court’s error affected a substantial right, the defendant must establish that there is a reasonable probability -9- Case No. 1-23-10 that, but for the trial court’s error, th

2004In order to find plain error, Crim.R. 52(B) requires that there be a deviation from a legal rule, the error must be an "obvious" defect in the trial proceedings, and the error must have affected a defendant's "substantial rights." State v. Barnes, 94 Ohio St.3d 21 , 27 , 2002-Ohio-68 .

13
State v. Whitegreen
· 2018 · cited in 1 Ohio opinions naming this issue, 2021–2021
1 sentence

2021Montgomery No. 27749, 2018-Ohio-3076, ¶ 27 (holding it was not a clear and unambiguous invocation of the right to remain silent where the suspect expressed that he “really do[es]n’t now even want to answer any questions”). 40 {¶176} “Invocation of the Miranda right to [remain silent] ‘requires, at a minimum, some statement that can reasonably be construed to be an expression of a desire [to cease all questioning].’” Davis at 459 , quoting McNeil v. Wisconsin, 501 U.S. 171, 178 , (1991). {¶177} Since we do not find Mr. Davis invoked his right to remain silent by informing the detectives that he

11
State v. Jackson, 06ap-1004 (5-22-2007)green
ohioctapp · 2007 · cited in 1 Ohio opinions naming this issue, 2008–2008
1 sentence

2008See, e.g., State v. Jackson , Franklin App. No. 06AP-1004, 2007-Ohio-2470 , at ¶ 10 .

11
Lilly v. Virginiagreen
scotus · 1999 · cited in 1 Ohio opinions naming this issue, 2004–2004
2 sentences

2004Moreover, those Justices — including Justice Scalia, the author of the Crawford opinion — who disagreed with the Court's pre- Crawford conclusion in Lilly v. Virginia, 527 U.S. 116 , 119 S.Ct. 1887 , 144 L.Ed.2d 117 (1999), that the admission of an accomplice's confession did not violate the Confrontation Clause, nonetheless concurred in the judgment because they believed that harmless error review applied to the perceived violation.

2004Moreover, those Justices — including Justice Scalia, the author of the Crawford opinion — who disagreed with the Court's pre- Crawford conclusion in Lilly v. Virginia, 527 U.S. 116 , 119 S.Ct. 1887 , 144 L.Ed.2d 117 (1999), that the admission of an accomplice's confession did not violate the Confrontation Clause, nonetheless concurred in the judgment because they believed that harmless error review applied to the perceived violation.

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 (8)

CaseCitedYears
State v. Barnes green
ohio · 2002
2 sentences

2004In order to find plain error, Crim.R. 52(B) requires that there be a deviation from a legal rule, the error must be an "obvious" defect in the trial proceedings, and the error must have affected a defendant's "substantial rights." State v. Barnes, 94 Ohio St.3d 21 , 27 , 2002-Ohio-68 .

2003In order to find plain error, Crim.R. 52(B) requires that there must be a deviation from a legal rule, the error must be an "obvious" defect in the trial proceedings, and the error must have affected a defendant's "substantial rights." State v. Barnes, 94 Ohio St.3d 21 , 27 , 2002-Ohio-68 .

22003–2004
State v. Sutton green
ohioctapp · 2022
1 sentence

2023Seneca No. 13-21-11, 2022-Ohio-2452, ¶ 50 .

12023–2023
McNeil v. Wisconsin green
scotus · 1991
1 sentence

2021Montgomery No. 27749, 2018-Ohio-3076, ¶ 27 (holding it was not a clear and unambiguous invocation of the right to remain silent where the suspect expressed that he “really do[es]n’t now even want to answer any questions”). 40 {¶176} “Invocation of the Miranda right to [remain silent] ‘requires, at a minimum, some statement that can reasonably be construed to be an expression of a desire [to cease all questioning].’” Davis at 459 , quoting McNeil v. Wisconsin, 501 U.S. 171, 178 , (1991). {¶177} Since we do not find Mr. Davis invoked his right to remain silent by informing the detectives that he

12021–2021
State v. Cabrales green
ohio · 2008
1 sentence

2008Instead, if, in comparing the elements of the offenses in the abstract, the offenses are so similar that the commission of one offense will necessarily result in commission of the other, then the offenses are allied offenses of similar import." State v. Cabrales , 118 Ohio St.3d 54 , 2008-Ohio-1625 , syllabus. {¶ 97} Ohio's burglary statute, R.C. 2911.12 , provides, in pertinent part: {¶ 98} "(A) No person, by force, stealth, or deception, shall do any of the following: {¶ 99} "* * * {¶ 100} "(2) Trespass in an occupied structure or in a separately secured or separately occupied portion of an

12008–2008
State ex rel. Royal v. Industrial Commission green
ohio · 2002
1 sentence

2007Id. {¶ 59} Citing Nicholls, Foster, and Gobich, relator claims that the commission lacked authority to exercise its continuing jurisdiction at the March 10, 1998 hearing before the SHO.

12007–2007
Blakemore v. Blakemore green
ohio · 1983
2 sentences

1997Blakemore v. Blakemore (1983), 5 Ohio St.3d 217 , 5 OBR 481, 450 N.E.2d 1140 .

1997Blakemore v. Blakemore (1983), 5 Ohio St.3d 217 , 5 OBR 481, 450 N.E.2d 1140 .

11997–1997
State v. Walker green
ohioctapp · 1981
2 sentences

1989State v. Walker (1981), 2 Ohio App.3d 483, 484 , 2 OBR 610, 611, 442 N.E.2d 1319, 1320-1321 , citing State v. Craft (1977), 52 Ohio App.2d 1 , 6 O.O.3d 1 , 367 N.E.2d 1221 .

1989State v. Walker (1981), 2 Ohio App.3d 483, 484 , 2 OBR 610, 611, 442 N.E.2d 1319, 1320-1321 , citing State v. Craft (1977), 52 Ohio App.2d 1 , 6 O.O.3d 1 , 367 N.E.2d 1221 .

11989–1989
State v. Craft green
ohioctapp · 1977
2 sentences

1989State v. Walker (1981), 2 Ohio App.3d 483, 484 , 2 OBR 610, 611, 442 N.E.2d 1319, 1320-1321 , citing State v. Craft (1977), 52 Ohio App.2d 1 , 6 O.O.3d 1 , 367 N.E.2d 1221 .

1989State v. Walker (1981), 2 Ohio App.3d 483, 484 , 2 OBR 610, 611, 442 N.E.2d 1319, 1320-1321 , citing State v. Craft (1977), 52 Ohio App.2d 1 , 6 O.O.3d 1 , 367 N.E.2d 1221 .

11989–1989

Statutes the citing opinions construe

OH § Ohio Rev. Code § 4123.52 (5)

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

PA 40 (1979–2026) NY 32 (1983–2026) TX 30 (1986–2022) VA 28 (1998–2025) FL 28 (1992–2023) IL 22 (1988–2026) OH 15 (1989–2023) CA 12 (1994–2025) RI 10 (2001–2021) OR 10 (1993–2025) LA 9 (2010–2019) SC 7 (2012–2025) MS 6 (2002–2012) NE 5 (2016–2025) NJ 5 (2001–2026) MI 5 (1980–2018) IN 4 (2002–2019) NM 4 (2010–2021) WA 4 (2021–2026) MO 3 (2016–2019) TN 3 (2005–2018) OK 3 (1994–2026) KY 3 (2005–2022) AZ 2 (1973–2024) KS 2 (2000–2018) MA 2 (2001–2020) MN 2 (1986–1986) CO 2 (2004–2010) WI 2 (2000–2015) CT 2 (2009–2014)

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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