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13 Ohio opinions name it 2 courts 2015–2026 7 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. Reynoldsgreen2 sentences2024“When sentencing an offender, a trial court must ‘[a]fford counsel an opportunity to speak on behalf of the defendant and address the defendant personally and ask if he or she wishes to make a statement in his or her own behalf or present any information in mitigation of punishment.’” State v. Johnson, 2017- Ohio-913, ¶ 5 (9th Dist.), quoting Crim.R. 32(A)(1). “‘R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing.’” Id., quoting Jackson, 2016-Ohio-8127, at ¶ 10 . “‘T 2018Summit No. 28268, 2017-Ohio-913, ¶ 5 , quoting Crim.R. 32(A)(1). “‘R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing.’” Id., quoting Jackson at ¶ 10 . “‘The purpose of allocution is to permit the defendant to speak on his own behalf or present any information in mitigation of punishment.’” Id., quoting State v. Reynolds, 80 Ohio St.3d 670, 684 (1998). -5- Case No. 7-18-24 {¶10} A trial court complies with a defendant’s right of allocution when it personally address | 3 | 3 |
State v. Frygreen2 sentences2024See State v. Fry, 2010-Ohio-1017, ¶ 186-188 ; Johnson at ¶ 6, quoting State v. Daniels, -9- Case No. 1-23-71 2013-Ohio-358, ¶ 14 (9th Dist.). 2018See State v. Fry, 125 Ohio St.3d 163 , 2010-Ohio-1017, ¶ 186-188 ; Johnson at ¶ 6, quoting State v. Daniels, 9th Dist. | 2 | 2 |
State v. Danielsgreen1 sentence2024See State v. Fry, 2010-Ohio-1017, ¶ 186-188 ; Johnson at ¶ 6, quoting State v. Daniels, -9- Case No. 1-23-71 2013-Ohio-358, ¶ 14 (9th Dist.). | 1 | 1 |
State v. Rodriguez-Barongreen1 sentence2015Mahoning No. 10-MA-176, 2012-Ohio-1473, ¶ 13 (Because a court of record speaks only through its journal entries, “the judgment entry, not the open court pronouncement of sentence, is the effective instrument for sentencing a defendant.”). {¶8} In Draughon, supra, the Tenth District considered an argument very similar to that raised by Roscoe here. | 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. Jackson (Slip Opinion)
green
2 sentences2026PAGE 8 OF 20 Case No. 2025-T-0062 (Emphasis added.) {¶21} Crim.R. 32(A)(1) provides, in relevant part, that “[a]t the time of imposing sentence, the court shall . . . [1] [a]fford counsel an opportunity to speak on behalf of the defendant and [2] address the defendant personally and ask if he or she wishes to make a statement in his or her own behalf or present any information in mitigation of punishment.” (Emphasis added.) The Supreme Court of Ohio has held that “R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial 2025"R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing." State v. Jackson, 2016-Ohio-8127, ¶ 10 , citing State v. Campbell, 90 Ohio St.3d 320 (2000), paragraph one of the syllabus. | 8 | 2017–2026 |
State v. Campbell
green
2 sentences2025"R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing." State v. Jackson, 2016-Ohio-8127, ¶ 10 , citing State v. Campbell, 90 Ohio St.3d 320 (2000), paragraph one of the syllabus. 2023As explained by the United States Supreme Court in Herring: It can hardly be questioned that closing argument serves to sharpen and clarify the issues for resolution by the trier of fact in a criminal case. 1 Crim.R. 32(A)(1), requires a court at sentencing to “address the defendant personally and ask if he or she wishes to make a statement in his or her own behalf or present any information in mitigation of punishment.” This rule “‘unambiguously require[s] that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing.’” State v. Jack | 7 | 2016–2025 |
State v. Roscoe
green
2 sentences2025Cuyahoga No. 102191, 2015-Ohio-3876, ¶ 7 , quoting State v. Rodriguez-Baron, 7th Dist. 2022Cuyahoga No. 102191, 2015-Ohio-3876, ¶ 7 , quoting State v. Rodriguez- Baron, 7th Dist. | 2 | 2022–2025 |
State v. Johnson
neutral
2 sentences2018Summit No. 28268, 2017-Ohio-913, ¶ 5 , quoting Crim.R. 32(A)(1). “‘R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing.’” Id., quoting Jackson at ¶ 10 . “‘The purpose of allocution is to permit the defendant to speak on his own behalf or present any information in mitigation of punishment.’” Id., quoting State v. Reynolds, 80 Ohio St.3d 670, 684 (1998). -5- Case No. 7-18-24 {¶10} A trial court complies with a defendant’s right of allocution when it personally address 2018Summit No. 28268, 2017-Ohio-913, ¶ 5 , quoting Crim.R. 32(A)(1). “‘R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing.’” Id., quoting Jackson at ¶ 10 . “‘The purpose of allocution is to permit the defendant to speak on his own behalf or present any information in mitigation of punishment.’” Id., quoting State v. Reynolds, 80 Ohio St.3d 670, 684 (1998). -5- Case No. 7-18-24 {¶10} A trial court complies with a defendant’s right of allocution when it personally address | 2 | 2018–2022 |
State v. Reynolds
green
1 sentence2026Specifically, R.C. 2929.19(B)(1)(a) provides that “[a]t the sentencing hearing, the court, before imposing sentence, shall . . . [c]onsider . . . any information presented at the hearing by any person pursuant to [R.C. 2929.19(A)] . . . .” (Emphasis added.) {¶23} The Supreme Court has explained that “[t]he purpose of allocution is to permit the defendant to speak on his [or her] own behalf or present any information in mitigation of punishment.” State v. Reynolds, 1998-Ohio-171, ¶ 76 . | 1 | 2026–2026 |
State v. Goldsberry
green
1 sentence2024“When sentencing an offender, a trial court must ‘[a]fford counsel an opportunity to speak on behalf of the defendant and address the defendant personally and ask if he or she wishes to make a statement in his or her own behalf or present any information in mitigation of punishment.’” State v. Johnson, 2017- Ohio-913, ¶ 5 (9th Dist.), quoting Crim.R. 32(A)(1). “‘R.C. 2929.19(A) and Crim.R. 32(A)(1) unambiguously require that an offender be given an opportunity for allocution whenever a trial court imposes a sentence at a sentencing hearing.’” Id., quoting Jackson, 2016-Ohio-8127, at ¶ 10 . “‘T | 1 | 2024–2024 |
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.