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14 Ohio opinions name it 2 courts 2007–2026 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 |
|---|---|---|
Henry C. Miller v. Rod Francis, Wardengreen2 sentences2026“When a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’” (Emphasis in original.) State v. Mundt, 2007- Ohio-4836, ¶ 67, quoting Miller v. Francis, 269 F.3d, 609, 616 (6th Cir. 2001). 2020Appellant focuses on Juror C.’s statements that he tended to believe children over adults and he might not be able to follow the law if appellant did not testify. {¶76} “When a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ (Emphasis added.)” State v. Mundt, 115 Ohio St.3d 22 , 2007-Ohio-4836 , 873 N.E.2d 828, ¶ 67 , quoting Miller v. Francis, 269 F.3d 609, 616 (6th Cir.2001). | 8 | 10 |
United States v. Woodgreen1 sentence2025We explained that “[w]hen a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ ” (Emphasis added in Mundt.) Id., quoting Miller at 616 , citing Hughes at 458 . {¶ 30} Actual bias means “‘bias in fact’—the existence of a state of mind that leads to an inference that the person will not act with entire impartiality.” United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997), citing United States v. Wood, 299 U.S. 123, 133 (1936). “‘[T]he mere existence | 1 | 1 |
Irvin v. Dowdgreen1 sentence2025State v. Warner, 55 Ohio St.3d 31, 47 (1990), quoting Irvin v. Dowd, 366 U.S. 717, 723 (1961). | 1 | 1 |
United States v. Torresgreen1 sentence2025We explained that “[w]hen a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ ” (Emphasis added in Mundt.) Id., quoting Miller at 616 , citing Hughes at 458 . {¶ 30} Actual bias means “‘bias in fact’—the existence of a state of mind that leads to an inference that the person will not act with entire impartiality.” United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997), citing United States v. Wood, 299 U.S. 123, 133 (1936). “‘[T]he mere existence | 1 | 1 |
State v. Warnergreen1 sentence2025State v. Warner, 55 Ohio St.3d 31, 47 (1990), quoting Irvin v. Dowd, 366 U.S. 717, 723 (1961). | 1 | 1 |
Smith v. Phillipsgreen2 sentences2007See also Goeders v. Hundley (C.A.8, 1995), 59 F.3d 73, 75 , citing Smith v. Phillips (1982), 455 U.S. 209, 215 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ; Carratelli v. State (Fla.App.2005), 915 So.2d 1256, 1260-1261 . {¶ 68} Although Mundt argues that Watson was biased, the record does not support that claim. 2007See also Goeders v. Hundley (C.A.8, 1995), 59 F.3d 73, 75 , citing Smith v. Phillips (1982), 455 U.S. 209, 215 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ; Carratelli v. State (Fla.App.2005), 915 So.2d 1256, 1260-1261 . {¶ 68} Although Mundt argues that Watson was biased, the record does not support that claim. | 1 | 1 |
Kline E. Goeders v. Thomas E. Hundleygreen1 sentence2007See also Goeders v. Hundley (C.A.8, 1995), 59 F.3d 73, 75 , citing Smith v. Phillips (1982), 455 U.S. 209, 215 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ; Carratelli v. State (Fla.App.2005), 915 So.2d 1256, 1260-1261 . {¶ 68} Although Mundt argues that Watson was biased, the record does not support that claim. | 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. Mundt
green
2 sentences2023As previously discussed, we will not second-guess such strategic decisions on appeal. {¶ 54} Moreover, “[w]hen a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ ” (Emphasis and citations omitted.) Mundt, 115 Ohio St.3d 22 , 2007-Ohio-4836 , 873 N.E.2d 828, at ¶ 67 . 2023As previously discussed, we will not second-guess such strategic decisions on appeal. {¶ 54} Moreover, “[w]hen a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ ” (Emphasis and citations omitted.) Mundt, 115 Ohio St.3d 22 , 2007-Ohio-4836 , 873 N.E.2d 828, at ¶ 67 . | 8 | 2014–2023 |
State v. Pickens (Slip Opinion)
green
2 sentences2020We explained that “[w]hen a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ ” (Emphasis added in Mundt.) Id., quoting Miller v. Francis at 616 . {¶ 86} We applied the actual-bias standard in State v. Pickens, 141 Ohio St.3d 462 , 2014-Ohio-5445 , 25 N.E.3d 1023 , another death-penalty case with facts remarkably similar to this one. 2020We explained that “[w]hen a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant ‘must show that the juror was actually biased against him.’ ” (Emphasis added in Mundt.) Id., quoting Miller v. Francis at 616 . {¶ 86} We applied the actual-bias standard in State v. Pickens, 141 Ohio St.3d 462 , 2014-Ohio-5445 , 25 N.E.3d 1023 , another death-penalty case with facts remarkably similar to this one. | 2 | 2016–2020 |
Marshall Dwayne Hughes v. United States
green
1 sentence2007When a defendant bases an ineffective-assistance claim on an assertion that his counsel allowed the impanelment of a biased juror, the defendant “must show that the juror was actually biased against him.” (Emphasis added.) Miller v. Francis, 269 F.3d at 616 , citing Hughes v. United States (C.A.6, 2001), 258 F.3d 453, 458 . | 1 | 2007–2007 |
Carratelli v. State
green
1 sentence2007See also Goeders v. Hundley (C.A.8, 1995), 59 F.3d 73, 75 , citing Smith v. Phillips (1982), 455 U.S. 209, 215 , 102 S.Ct. 940 , 71 L.Ed.2d 78 ; Carratelli v. State (Fla.App.2005), 915 So.2d 1256, 1260-1261 . {¶ 68} Although Mundt argues that Watson was biased, the record does not support that claim. | 1 | 2007–2007 |
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.