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14 Ohio opinions name it 2 courts 2008–2021 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.
| Case | Followed | Cited |
|---|---|---|
State v. McDonaldgreen1 sentence2021Clermont No. CA2013-07-056, 2014-Ohio-989, ¶ 38 ("trial court properly vacated appellant's classification under the Adam Walsh Act and held a reclassification hearing to determine appellant's status as a sex offender under Megan's Law"). - 10 - Butler CA2020-07-080 {¶30} Jones' argument that Henderson means the unlawful application of the Adam Walsh Act rendered his sentence voidable in 2008, and therefore final when it was not appealed, misses the point. | 1 | 1 |
State v. Bradleygreen1 sentence2014Strickland v. Washington, 466 U.S. 668, 687 , 104 S.Ct. 2052 (1984); State v. Bradley, 42 Ohio St.3d 136, 141-142 (1989). | 1 | 1 |
In re R.A.green1 sentence2014The court then provided notification and registration requirements. {¶7} Miller appealed, raising the following assigned error: Appellant’s classification as a Tier II sex offender was unconstitutional and void and the trial court lacked jurisdiction to conduct a reclassification hearing pursuant to Megan’s Law because appellant had completed serving his sentence and therefore appellant’s reclassification as a sexual oriented offender is void. {¶8} Ohio courts have consistently held that a sex-offender classification proceeding under Megan’s Law is civil in nature and “distinct from the procee | 1 | 1 |
State v. Rabergreen2 sentences2014The court then provided notification and registration requirements. {¶7} Miller appealed, raising the following assigned error: Appellant’s classification as a Tier II sex offender was unconstitutional and void and the trial court lacked jurisdiction to conduct a reclassification hearing pursuant to Megan’s Law because appellant had completed serving his sentence and therefore appellant’s reclassification as a sexual oriented offender is void. {¶8} Ohio courts have consistently held that a sex-offender classification proceeding under Megan’s Law is civil in nature and “distinct from the procee 2014The court then provided notification and registration requirements. {¶7} Miller appealed, raising the following assigned error: Appellant’s classification as a Tier II sex offender was unconstitutional and void and the trial court lacked jurisdiction to conduct a reclassification hearing pursuant to Megan’s Law because appellant had completed serving his sentence and therefore appellant’s reclassification as a sexual oriented offender is void. {¶8} Ohio courts have consistently held that a sex-offender classification proceeding under Megan’s Law is civil in nature and “distinct from the procee | 1 | 1 |
State v. Williamsgreen2 sentences2014The court then provided notification and registration requirements. {¶7} Miller appealed, raising the following assigned error: Appellant’s classification as a Tier II sex offender was unconstitutional and void and the trial court lacked jurisdiction to conduct a reclassification hearing pursuant to Megan’s Law because appellant had completed serving his sentence and therefore appellant’s reclassification as a sexual oriented offender is void. {¶8} Ohio courts have consistently held that a sex-offender classification proceeding under Megan’s Law is civil in nature and “distinct from the procee 2014The court then provided notification and registration requirements. {¶7} Miller appealed, raising the following assigned error: Appellant’s classification as a Tier II sex offender was unconstitutional and void and the trial court lacked jurisdiction to conduct a reclassification hearing pursuant to Megan’s Law because appellant had completed serving his sentence and therefore appellant’s reclassification as a sexual oriented offender is void. {¶8} Ohio courts have consistently held that a sex-offender classification proceeding under Megan’s Law is civil in nature and “distinct from the procee | 1 | 1 |
Palazzi v. Estate of Gardnergreen1 sentence2009See Palazzi , 32 Ohio St. 3d 169 , at syllabus. | 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. Schulze
neutral
2 sentences2019Further, at the reclassification hearing, the trial court must determine whether the specific tier classification in which the child has been placed is proper and if it should be continued or modified. {¶11} In State v. Schulze, 2016-Ohio-470 , 59 N.E.3d 673 (1st Dist.), the juvenile court had correctly entered an initial classification order under Megan’s Law, former R.C. 2017Further, at the reclassification hearing, the trial court must determine whether the specific tier classification in which the child has been placed is proper and if it should be continued or modified. {¶8} We held in State v. Schulze, 2016-Ohio-470 , 59 N.E.3d 673 (1st Dist.), that where the juvenile court had correctly held the initial classification hearing under Megan’s Law, but had erroneously held the completion-of- disposition hearing under the Adam Walsh Act, the order entered after the second hearing classifying Schulze under the Adam Walsh Act was void, and there was no valid order i | 2 | 2017–2019 |
State v. Wilson
green
2 sentences2014State v. Wilson, 113 Ohio St.3d 382 , 2007-Ohio-2202 , -6- Butler CA2013-05-082 ¶ 32. 2014The court then provided notification and registration requirements. {¶7} Miller appealed, raising the following assigned error: Appellant’s classification as a Tier II sex offender was unconstitutional and void and the trial court lacked jurisdiction to conduct a reclassification hearing pursuant to Megan’s Law because appellant had completed serving his sentence and therefore appellant’s reclassification as a sexual oriented offender is void. {¶8} Ohio courts have consistently held that a sex-offender classification proceeding under Megan’s Law is civil in nature and “distinct from the procee | 2 | 2014–2014 |
State v. Bellman
green
2 sentences2021State v. Bellman, 86 Ohio St.3d 208 , 714 N.E.2d 381 (1999) (the statutory requirement regarding the timing of a sexual-predator hearing is not jurisdictional and a defendant may waive it); State v. Sturgill, 2017-Ohio-2736 , 90 N.E.3d 44 (4th Dist.) (the trial court had jurisdiction to conduct the reclassification hearing after the defendant had served his prison sentence and had been released for two years); State v. Bell, 12th Dist. 2021State v. Bellman, 86 Ohio St.3d 208 , 714 N.E.2d 381 (1999) (the statutory requirement regarding the timing of a sexual-predator hearing is not jurisdictional and a defendant may waive it); State v. Sturgill, 2017-Ohio-2736 , 90 N.E.3d 44 (4th Dist.) (the trial court had jurisdiction to conduct the reclassification hearing after the defendant had served his prison sentence and had been released for two years); State v. Bell, 12th Dist. | 1 | 2021–2021 |
State v. Bell
green
1 sentence2021Clermont No. CA2015-10-077, 2016-Ohio-7363 (the language in former R.C. 2950.09(B) referring to the timing of the sexual- predator hearing was not jurisdictional and the trial court had jurisdiction to classify the defendant a year after he had been released from prison); State v. Jones, 12th Dist. | 1 | 2021–2021 |
State v. Sturgill
green
2 sentences2021State v. Bellman, 86 Ohio St.3d 208 , 714 N.E.2d 381 (1999) (the statutory requirement regarding the timing of a sexual-predator hearing is not jurisdictional and a defendant may waive it); State v. Sturgill, 2017-Ohio-2736 , 90 N.E.3d 44 (4th Dist.) (the trial court had jurisdiction to conduct the reclassification hearing after the defendant had served his prison sentence and had been released for two years); State v. Bell, 12th Dist. 2021State v. Bellman, 86 Ohio St.3d 208 , 714 N.E.2d 381 (1999) (the statutory requirement regarding the timing of a sexual-predator hearing is not jurisdictional and a defendant may waive it); State v. Sturgill, 2017-Ohio-2736 , 90 N.E.3d 44 (4th Dist.) (the trial court had jurisdiction to conduct the reclassification hearing after the defendant had served his prison sentence and had been released for two years); State v. Bell, 12th Dist. | 1 | 2021–2021 |
Strickland v. Washington
green
2 sentences2014Strickland v. Washington, 466 U.S. 668, 687 , 104 S.Ct. 2052 (1984); State v. Bradley, 42 Ohio St.3d 136, 141-142 (1989). 2014Strickland v. Washington, 466 U.S. 668, 687 , 104 S.Ct. 2052 (1984); State v. Bradley, 42 Ohio St.3d 136, 141-142 (1989). | 1 | 2014–2014 |
State v. Hayden
green
1 sentence2014State v. Hayden, 96 Ohio St.3d 211 , 2002-Ohio-4169 , 773 N.E.2d 502 , ¶ 18. {¶10} In the present case, Miller was convicted of gross sexual imposition, which, by its definition, is a sexually oriented offense under Megan’s Law because it involves sexual contact. | 1 | 2014–2014 |
State v. Roberts
green
2 sentences2014Accordingly, ‘a criminal defendant whose conviction is no longer subject to appellate review has no unqualified right to a transcript at state’s expense.’ State v. Roberts, 66 Ohio App.3d 654, 656 , 585 N.E.2d 934 (9th Dist. 2014Accordingly, ‘a criminal defendant whose conviction is no longer subject to appellate review has no unqualified right to a transcript at state’s expense.’ State v. Roberts, 66 Ohio App.3d 654, 656 , 585 N.E.2d 934 (9th Dist. | 1 | 2014–2014 |
State v. Hayden
green
1 sentence2014State v. Hayden, 96 Ohio St.3d 211 , 2002-Ohio-4169 , 773 N.E.2d 502 , ¶ 18. {¶10} In the present case, Miller was convicted of gross sexual imposition, which, by its definition, is a sexually oriented offense under Megan’s Law because it involves sexual contact. | 1 | 2014–2014 |
State v. Hanna
green
1 sentence2014Butler No. CA2011-09-169, 2013-Ohio-856, ¶ 32 ; State v. Hanna, 95 Ohio St.3d 285 , 2002- Ohio-2221, ¶ 118. | 1 | 2014–2014 |
State ex rel. Fontanella v. Kontos
neutral
1 sentence2014Fontanella v. Kontos, 117 Ohio St.3d 514 , 2008-Ohio-1431 , 885 N.E.2d 220 , ¶ 6. {¶ 6} Clay argues that Judge Gee failed to perform his duty because the judge allegedly violated the law in the course of conducting the reclassification hearing. | 1 | 2014–2014 |
State ex rel. Jean-Baptiste v. Kirsch
green
2 sentences2014Jean-Baptiste v. Kirsch, 134 Ohio St.3d 421 , 2012-Ohio-5697 . 2014Jean-Baptiste v. Kirsch, 134 Ohio St.3d 421 , 2012-Ohio-5697 . | 1 | 2014–2014 |
State v. Clay
neutral
1 sentence2014Chapter 2950. * * * [Cite as State v. Clay, 2014-Ohio-950 .] The court provided notice to Clay of his 10-year registration duties. {¶ 9} We note that Clay filed multiple requests for a transcript of the reclassification hearing, at the State’s expense, and that this Court denied his request on October 15, 2013, noting that post-conviction “relief is a civil proceeding. | 1 | 2014–2014 |
State v. Johnson
green
1 sentence2014Butler No. CA2011-09-169, 2013-Ohio-856, ¶ 32 ; State v. Hanna, 95 Ohio St.3d 285 , 2002- Ohio-2221, ¶ 118. | 1 | 2014–2014 |
State v. Bodyke
green
2 sentences2012Accordingly, the trial court did not err when it refused to hold a reclassification hearing and overruled his motion to dismiss. {¶ 13} R.C. 2950.05(A) provides that if an offender is required to register under R.C. 2950.04, then he “ * * * shall provide written notice of any change of residence address * * * to the sheriff * * * at least twenty days prior to changing the address of the residence.” R.C. 2950.05(F)(1) provides, “No person who is required to notify a sheriff of a change of address pursuant to division (A) of this section * * * shall fail to notify the appropriate sheriff in acco 2012Accordingly, the trial court did not err when it refused to hold a reclassification hearing and overruled his motion to dismiss. {¶ 13} R.C. 2950.05(A) provides that if an offender is required to register under R.C. 2950.04, then he “ * * * shall provide written notice of any change of residence address * * * to the sheriff * * * at least twenty days prior to changing the address of the residence.” R.C. 2950.05(F)(1) provides, “No person who is required to notify a sheriff of a change of address pursuant to division (A) of this section * * * shall fail to notify the appropriate sheriff in acco | 1 | 2012–2012 |
Chojnacki v. Cordray
green
2 sentences2011No. 10AP-932, 2011-Ohio-2009 . {¶ 12} The Hazlett court analyzed the Bodyke holding in light of Chojnacki v. Cordray, 126 Ohio St.3d 321 , 2010-Ohio-3212 , 933 N.E.2d 800 , which was decided shortly after Bodyke. {¶ 13} “The Supreme Court of Ohio in Chojnacki reiterated, ‘In Bodyke, we severed R.C. 2950.031 and 2950.032, the reclassification provisions of the Adam Walsh Act, and held that after severance, those provisions could not be enforced.’ Noting that the reclassification hearing that resulted in the appeal and the related certified question ‘arose under the now-severed provisions of R.C 2011No. 10AP-932, 2011-Ohio-2009 . {¶ 12} The Hazlett court analyzed the Bodyke holding in light of Chojnacki v. Cordray, 126 Ohio St.3d 321 , 2010-Ohio-3212 , 933 N.E.2d 800 , which was decided shortly after Bodyke. {¶ 13} “The Supreme Court of Ohio in Chojnacki reiterated, ‘In Bodyke, we severed R.C. 2950.031 and 2950.032, the reclassification provisions of the Adam Walsh Act, and held that after severance, those provisions could not be enforced.’ Noting that the reclassification hearing that resulted in the appeal and the related certified question ‘arose under the now-severed provisions of R.C | 1 | 2011–2011 |
State v. Foster
green
1 sentence2008On September 14, 2006, this court affirmed appellant's convictions, but vacated the sexual predator finding and remanded for resentencing under State v. Foster , 109 St.3d 1, 2006-Ohio-856 , 845 N.E.2d 470 . *Page 4 {¶ 6} On June 29, 2007, the trial court held a resentencing hearing and a reclassification hearing. | 1 | 2008–2008 |
State v. Carter, Unpublished Decision (11-30-2007)
neutral
1 sentence2008No. L-07-1088, 2007-Ohio-6359 . | 1 | 2008–2008 |
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.