Caldwell violation (Ohio) · Go Syfert
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Caldwell violation in Ohio

14 Ohio opinions name it 2 courts 1989–2025 4 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 (11)

CaseFollowedCited
State v. Daviegreen
ohio · 1997 · cited in 3 Ohio opinions naming this issue, 2002–2003
2 sentences

2003See, e.g., State v. Durr (1991), 58 Ohio St.3d 86, 93 , 568 N.E.2d 674 ; State v. Davie (1997), 80 Ohio St.3d 311, 326-327 , 686 N.E.2d 245 .

2003See, e.g., State v. Durr (1991), 58 Ohio St.3d 86, 93 , 568 N.E.2d 674 ; State v. Davie (1997), 80 Ohio St.3d 311, 326-327 , 686 N.E.2d 245 .

23
State v. Durrgreen
ohio · 1991 · cited in 3 Ohio opinions naming this issue, 2002–2003
2 sentences

2003See, e.g., State v. Durr (1991), 58 Ohio St.3d 86, 93 , 568 N.E.2d 674 ; State v. Davie (1997), 80 Ohio St.3d 311, 326-327 , 686 N.E.2d 245 .

2003See, e.g., State v. Durr (1991), 58 Ohio St.3d 86, 93 , 568 N.E.2d 674 ; State v. Davie (1997), 80 Ohio St.3d 311, 326-327 , 686 N.E.2d 245 .

13
State v. Smithgreen
ohioctapp · 2023 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025E.g., State v. Sanchez, 2014-Ohio-2263, ¶ 26 (8th Dist.) (plain error review did not apply because the defendant moved for leave to withdraw his guilty plea, thus bringing the validity of the guilty plea to the trial court’s attention); State v. Smith, 2023-Ohio-1235, ¶ 12 (4th Dist.) (plain error review did not apply because appellant brought the issue to the trial court’s attention through a motion that the trial court effectively denied). -13- Case No. 3-24-17 {¶21} Finally, it is worth noting that the verdict form in this case is distinguishable from the verdict form discussed in State v.

11
State v. Sanchezgreen
ohioctapp · 2014 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025E.g., State v. Sanchez, 2014-Ohio-2263, ¶ 26 (8th Dist.) (plain error review did not apply because the defendant moved for leave to withdraw his guilty plea, thus bringing the validity of the guilty plea to the trial court’s attention); State v. Smith, 2023-Ohio-1235, ¶ 12 (4th Dist.) (plain error review did not apply because appellant brought the issue to the trial court’s attention through a motion that the trial court effectively denied). -13- Case No. 3-24-17 {¶21} Finally, it is worth noting that the verdict form in this case is distinguishable from the verdict form discussed in State v.

11
Caldwell v. Whirlpool Corp.green
ohioctapp · 2023 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024It held that “pursuant to * * * Chatfield, Caldwell’s claim had expired by operation of law by January 11, 2022.” 2023-Ohio-1530, ¶ 13.

2024It held that “pursuant to * * * Chatfield, Caldwell’s claim had expired by operation of law by January 11, 2022.” 2023-Ohio-1530, ¶ 13 .

11
Youghiogheny & Ohio Coal Co. v. Mayfieldgreen
ohio · 1984 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See R.C. 4123.512(A); Youghiogheny, 11 Ohio St.3d at 71, 464 N.E.2d 133; Fisher, 30 Ohio St.3d 8, 505 N.E.2d 975, paragraph one of the syllabus.

2024See R.C. 4123.512(A); Youghiogheny, 11 Ohio St.3d at 71, 464 N.E.2d 133; Fisher, 30 Ohio St.3d 8, 505 N.E.2d 975, paragraph one of the syllabus.

11
Chapman v. Jagogreen
ohio · 1976 · cited in 1 Ohio opinions naming this issue, 2014–2014
1 sentence

2014Appellant’s remedy, if any, is by way of appeal from the judgment of conviction.” Chapman v. Jago, 48 Ohio St.2d 51, 51 (1976). {¶9} Accordingly, Mr. Caldwell’s contention that the trial court lacked subject matter jurisdiction due to the lack of signature on the first indictment lacks merit. {¶10} However, as the trial court found Mr. Caldwell’s motion to be “untimely,” it appears that the trial court considered whether Mr. Caldwell’s motion could be successful if construed as a petition for post-conviction relief.

11
State v. Hughbanksgreen
ohio · 2003 · cited in 1 Ohio opinions naming this issue, 2014–2014
2 sentences

2014See State v. Hughbanks, 99 Ohio St.3d 365 , 2003-Ohio-4121 , 792 N.E.2d 1081, ¶ 102 . d.

2014See State v. Hughbanks, 99 Ohio St.3d 365 , 2003-Ohio-4121 , 792 N.E.2d 1081, ¶ 102 . d.

11
State v. LaMargreen
ohio · 2002 · cited in 1 Ohio opinions naming this issue, 2003–2003
1 sentence

2003See State v. LaMar, 95 Ohio St.3d 181 , 2002-Ohio-2128 , 767 N.E.2d 166, ¶ 109 .

11
State v. LaMargreen
ohio · 2002 · cited in 1 Ohio opinions naming this issue, 2003–2003
2 sentences

2003See State v. LaMar, 95 Ohio St.3d 181 , 2002-Ohio-2128 , 767 N.E.2d 166, ¶ 109 .

2003See State v. LaMar, 95 Ohio St.3d 181 , 2002-Ohio-2128 , 767 N.E.2d 166, ¶ 109 .

11
State v. Hicksgreen
ohio · 1989 · cited in 1 Ohio opinions naming this issue, 1989–1989
2 sentences

1989Ed. 2d 435, 443 , 109 S. Ct. 1211, 1215 ; see, also, State v. Hicks (1989), 43 Ohio St. 3d 72, 79-80 , 538 N.E. 2d 1030, 1038-1039 .

1989Ed. 2d 435, 443 , 109 S. Ct. 1211, 1215 ; see, also, State v. Hicks (1989), 43 Ohio St. 3d 72, 79-80 , 538 N.E. 2d 1030, 1038-1039 .

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 (13)

CaseCitedYears
Dugger v. Adams green
scotus · 1989
2 sentences

2014But when a defendant claims that a Caldwell violation occurred, he or she “must show that the remarks to the jury improperly described the role assigned to the jury by local law.” Dugger v. Adams, 489 U.S. 401, 407 , 109 S.Ct. 1211 , 103 L.Ed.2d 435 (1989).

2014But when a defendant claims that a Caldwell violation occurred, he or she “must show that the remarks to the jury improperly described the role assigned to the jury by local law.” Dugger v. Adams, 489 U.S. 401, 407 , 109 S.Ct. 1211 , 103 L.Ed.2d 435 (1989).

61989–2021
Robert A. Buell v. Betty Mitchell, Warden green
ca6 · 2001
2 sentences

2002To establish a Caldwell violation, however, a defendant “ ‘necessarily must show that the remarks to the jury improperly described the role assigned to the jury by local law.’ ” Buell v. Mitchell (C.A.6, 2001), 274 F.3d 337, 353 , quoting Dugger v. Adams (1989), 489 U.S. 401, 407 , 109 S.Ct. 1211 , 103 L.Ed.2d 435 .

2002To establish a Caldwell violation, however, a defendant “ ‘necessarily must show that the remarks to the jury improperly described the role assigned to the jury by local law.’ ” Buell v. Mitchell (C.A.6, 2001), 274 F.3d 337, 353 , quoting Dugger v. Adams (1989), 489 U.S. 401, 407 , 109 S.Ct. 1211 , 103 L.Ed.2d 435 .

22002–2002
Shaver v. Wolske & Blue green
ohioctapp · 2000
2 sentences

2025Shaver v. Wolske & Blue, 138 Ohio App.3d 653 (10th Dist. 2000.) In our case, Ms. Webb was faced with a choice: to take additional leave without pay and medical benefits, or to retire and receive some income and medical coverage from OPERS.

2025Shaver v. Wolske & Blue, 138 Ohio App.3d 653 (10th Dist. 2000.) In our case, Ms. Webb was faced with a choice: to take additional leave without pay and medical benefits, or to retire and receive some income and medical coverage from OPERS.

12025–2025
Fisher v. Mayfield green
ohio · 1987
2 sentences

2024See R.C. 4123.512(A); Youghiogheny, 11 Ohio St.3d at 71, 464 N.E.2d 133; Fisher, 30 Ohio St.3d 8, 505 N.E.2d 975, paragraph one of the syllabus.

2024See R.C. 4123.512(A); Youghiogheny, 11 Ohio St.3d at 71, 464 N.E.2d 133; Fisher, 30 Ohio St.3d 8, 505 N.E.2d 975, paragraph one of the syllabus.

12024–2024
Romano v. Oklahoma green
scotus · 1994
2 sentences

2021Second, Lynch must show that the remarks to the jury “ ‘improperly described the role assigned to the jury by local law.’ ” Romano v. Oklahoma, 512 U.S. 1, 9 , 114 S.Ct. 2004 , 129 L.Ed.2d 1 (1994), quoting Dugger v. Adams, 489 U.S. 401, 407 , 109 S.Ct. 1211 , 103 L.Ed.2d 435 (1989). {¶28} During Lynch’s trial, the prosecutor, trial court, and defense counsel all informed the jury that it could recommend that Lynch be sentenced to death.

2021Second, Lynch must show that the remarks to the jury “ ‘improperly described the role assigned to the jury by local law.’ ” Romano v. Oklahoma, 512 U.S. 1, 9 , 114 S.Ct. 2004 , 129 L.Ed.2d 1 (1994), quoting Dugger v. Adams, 489 U.S. 401, 407 , 109 S.Ct. 1211 , 103 L.Ed.2d 435 (1989). {¶28} During Lynch’s trial, the prosecutor, trial court, and defense counsel all informed the jury that it could recommend that Lynch be sentenced to death.

12021–2021
Caldwell v. Mississippi green
scotus · 1985
1 sentence

2021To succeed on his Caldwell claim, Lynch must first show that remarks made during the penalty phase erroneously “minimize[d] the jury’s sense of responsibility for determining the appropriateness of death.” Id. at 341 .

12021–2021
State v. Reynolds green
ohio · 1997
1 sentence

2014R.C. 2953.21(A)(1)(a) provides that “[a]ny person who has been convicted of a criminal offense * * * and who claims that there was such a denial or infringement of the person’s rights as to render the judgment void or voidable under the Ohio Constitution or the Constitution of the United States, * * * may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the court to vacate or set aside the judgment or sentence or to grant other appropriate relief.” Therefore, “[w]here a criminal defendant, subsequent to his or her direct appeal, files a

12014–2014
State v. White green
ohio · 2012
1 sentence

2014Nor does Mr. Caldwell claim to have a vested right in not being subject to registration requirements at the time he committed his offense. {¶32} With regard to the imposition of retroactive burdens, the White court confirmed that—except as to the prohibition against ex post facto laws—the commission of an offense does not give felons a “ ‘reasonable right to expect that their conduct will never thereafter be made the subject of legislation.’ ” White, 132 Ohio St.3d 344 , 2012- Ohio-2583, 972 N.E.2d 534 , at ¶ 43, quoting Matz at 281-282 .

12014–2014
Temple v. Wean United, Inc. green
ohio · 1977
2 sentences

2004As such, and based on the foregoing, appellant’s waiver argument lacks merit. {¶ 106} Thus, all of appellant’s arguments under its first assignment of error lack merit and are hereby overruled. {¶ 107} Appellant’s second assignment of error asserts: {¶ 108} “The trial court erred in granting defendant-appellee Village of Caldwell’s motion for summary judgment on plaintiff-appellant Seneca Valley, Inc.’s claim for unjust enrichment (September 9, 2002 Journal Entry.)” {¶ 109} Appellant initially asserts that the trial court’s decision to grant the Village summary judgment as to appellant’s secon

2004As such, and based on the foregoing, appellant’s waiver argument lacks merit. {¶ 106} Thus, all of appellant’s arguments under its first assignment of error lack merit and are hereby overruled. {¶ 107} Appellant’s second assignment of error asserts: {¶ 108} “The trial court erred in granting defendant-appellee Village of Caldwell’s motion for summary judgment on plaintiff-appellant Seneca Valley, Inc.’s claim for unjust enrichment (September 9, 2002 Journal Entry.)” {¶ 109} Appellant initially asserts that the trial court’s decision to grant the Village summary judgment as to appellant’s secon

12004–2004
Marshall v. Aaron green
ohio · 1984
2 sentences

2004As such, and based on the foregoing, appellant’s waiver argument lacks merit. {¶ 106} Thus, all of appellant’s arguments under its first assignment of error lack merit and are hereby overruled. {¶ 107} Appellant’s second assignment of error asserts: {¶ 108} “The trial court erred in granting defendant-appellee Village of Caldwell’s motion for summary judgment on plaintiff-appellant Seneca Valley, Inc.’s claim for unjust enrichment (September 9, 2002 Journal Entry.)” {¶ 109} Appellant initially asserts that the trial court’s decision to grant the Village summary judgment as to appellant’s secon

2004As such, and based on the foregoing, appellant’s waiver argument lacks merit. {¶ 106} Thus, all of appellant’s arguments under its first assignment of error lack merit and are hereby overruled. {¶ 107} Appellant’s second assignment of error asserts: {¶ 108} “The trial court erred in granting defendant-appellee Village of Caldwell’s motion for summary judgment on plaintiff-appellant Seneca Valley, Inc.’s claim for unjust enrichment (September 9, 2002 Journal Entry.)” {¶ 109} Appellant initially asserts that the trial court’s decision to grant the Village summary judgment as to appellant’s secon

12004–2004
Inland Refuse Transfer Co. v. Browning-Ferris Industries of Ohio, Inc. green
ohio · 1984
2 sentences

2004“However, if a term cannot be determined from the four corners of a contract, [a] factual determination of intent or reasonableness may be necessary to supply the *634 missing term.” Inland Refuse Transfer Co. v. Browning-Ferris Industries of Ohio, Inc. (1984), 15 Ohio St.3d 321, 322 , 15 OBR 448, 474 N.E.2d 271 , citing Hallet & Davis Piano Co. v. Starr Piano Co. (1911), 85 Ohio St. 196 , 97 N.E. 377 . {¶ 29} Appellant’s first assignment of error asserts: {¶ 30} “The trial court erred in granting defendant-appellee Village of Caldwell’s motion for summary judgment on plaintiff-appellant Senec

2004“However, if a term cannot be determined from the four corners of a contract, [a] factual determination of intent or reasonableness may be necessary to supply the *634 missing term.” Inland Refuse Transfer Co. v. Browning-Ferris Industries of Ohio, Inc. (1984), 15 Ohio St.3d 321, 322 , 15 OBR 448, 474 N.E.2d 271 , citing Hallet & Davis Piano Co. v. Starr Piano Co. (1911), 85 Ohio St. 196 , 97 N.E. 377 . {¶ 29} Appellant’s first assignment of error asserts: {¶ 30} “The trial court erred in granting defendant-appellee Village of Caldwell’s motion for summary judgment on plaintiff-appellant Senec

12004–2004
Allied Erecting & Dismantling Co. v. Uneco Realty Co. green
ohioctapp · 2001
2 sentences

2004Allied Erecting & Dismantling Co. v. Uneco Realty Co. (2001), 146 Ohio App.3d 136, 142 , 765 N.E.2d 420 . {¶ 32} The existence of the contract is undisputed.

2004Allied Erecting & Dismantling Co. v. Uneco Realty Co. (2001), 146 Ohio App.3d 136, 142 , 765 N.E.2d 420 . {¶ 32} The existence of the contract is undisputed.

12004–2004
State v. Wills green
ohio · 1994
2 sentences

1996After completing this task they then targeted Thomas, surrounded him, pulled out a gun, and then robbed him.” Wills, 69 Ohio St.3d at 691 , 635 N.E.2d at 371 .

1996After completing this task they then targeted Thomas, surrounded him, pulled out a gun, and then robbed him.” Wills, 69 Ohio St.3d at 691 , 635 N.E.2d at 371 .

11996–1996

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2929.04 (7) OH § Ohio Rev. Code § 2929.03 (6) OH § Ohio Rev. Code § 2929.05 (6) OH § Ohio Rev. Code § 2903.01 (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

FL 32 (1987–2025) CA 25 (1989–2020) OH 14 (1989–2025) IL 13 (1992–2024) TN 12 (1989–2010) PA 9 (1986–2025) IN 9 (1990–2019) MS 8 (2001–2010) MO 6 (1991–2015) TX 6 (2008–2024) GA 6 (1997–2023) NC 3 (1994–1995) KY 3 (1978–2010) MN 3 (2005–2016) AR 3 (2006–2019) KS 3 (2001–2017) ID 2 (2013–2013) AZ 2 (2008–2012) DE 2 (2001–2005) OK 2 (1994–1997) NJ 2 (2002–2004) AL 2 (1987–2015) VA 2 (1986–1991)

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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