actual-prejudice standard (Ohio) · Go Syfert
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actual-prejudice standard in Ohio

12 Ohio opinions name it 2 courts 2016–2025 5 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 (1)

CaseFollowedCited
State v. Jones (Slip Opinion)green
ohio · 2016 · cited in 5 Ohio opinions naming this issue, 2017–2025
2 sentences

2025“That does not mean, however, that demonstrably faded memories and actually unavailable witnesses or lost evidence cannot satisfy the actual-prejudice requirement.” Id.

2025But that “does not mean . . . that demonstrably faded memories and actually unavailable witnesses or lost evidence cannot satisfy the actual-prejudice requirement.” Jones at ¶ 21.

15

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 (6)

CaseCitedYears
State v. Luck green
ohio · 1984
2 sentences

2017The Ohio Supreme Court remanded the case for the court of appeals to make the appropriate determination “in the first instance,” applying the two-part burden-shifting analysis enunciated in State v. Whiting, 84 Ohio St.3d 215, 217 , 1998-Ohio-575 , 702 N.E.2d 1199 , and the actual-prejudice standard from State v. Luck, 15 Ohio St.3d 150 , 472 N.E.2d 1097 (1984).

2017The Ohio Supreme Court remanded the case for the court of appeals to make the appropriate determination “in the first instance,” applying the two-part burden-shifting analysis enunciated in State v. Whiting, 84 Ohio St.3d 215, 217 , 1998-Ohio-575 , 702 N.E.2d 1199 , and the actual-prejudice standard from State v. Luck, 15 Ohio St.3d 150 , 472 N.E.2d 1097 (1984).

42016–2018
State v. Adams (Slip Opinion) green
ohio · 2015
2 sentences

2018(Emphasis sic.) “Those are ‘the real possibilit[ies] of prejudice inherent in any extended delay,’ and statutes of limitations sufficiently protect against them.” Id., citing Marion, 404 U.S. at 326 , 92 S.Ct. 455 , 30 L.Ed.2d 468 . {¶17} “That does not mean, however, that demonstrably faded memories and actually unavailable witnesses or lost evidence cannot satisfy the actual-prejudice requirement.” Id.

2018(Emphasis sic.) "Those are 'the real possibilit[ies] of prejudice inherent in any extended delay,' and statutes of limitations sufficiently protect against them." Id. , citing Marion , 404 U.S. at 326 , 92 S.Ct. 455 , 30 L.Ed.2d 468 . {¶ 17} "That does not mean, however, that demonstrably faded memories and actually unavailable witnesses or lost evidence cannot satisfy the actual-prejudice requirement." Id.

32017–2021
United States v. Marion green
scotus · 1971
2 sentences

2019“That does not mean, however, that demonstrably faded memories and actually unavailable witnesses or lost evidence cannot satisfy the actual-prejudice requirement.” Id.

2018(Emphasis sic.) "Those are 'the real possibilit[ies] of prejudice inherent in any extended delay,' and statutes of limitations sufficiently protect against them." Id. , citing Marion , 404 U.S. at 326 , 92 S.Ct. 455 , 30 L.Ed.2d 468 . {¶ 17} "That does not mean, however, that demonstrably faded memories and actually unavailable witnesses or lost evidence cannot satisfy the actual-prejudice requirement." Id.

32018–2019
State v. Whiting green
ohio · 1998
2 sentences

2017The Ohio Supreme Court remanded the case for the court of appeals to make the appropriate determination “in the first instance,” applying the two-part burden-shifting analysis enunciated in State v. Whiting, 84 Ohio St.3d 215, 217 , 1998-Ohio-575 , 702 N.E.2d 1199 , and the actual-prejudice standard from State v. Luck, 15 Ohio St.3d 150 , 472 N.E.2d 1097 (1984).

2017The Ohio Supreme Court remanded the case for the court of appeals to make the appropriate determination “in the first instance,” applying the two-part burden-shifting analysis enunciated in State v. Whiting, 84 Ohio St.3d 215, 217 , 1998-Ohio-575 , 702 N.E.2d 1199 , and the actual-prejudice standard from State v. Luck, 15 Ohio St.3d 150 , 472 N.E.2d 1097 (1984).

32016–2017
State v. McCoy green
ohioctapp · 2019
2 sentences

2022Cuyahoga No. 107029, 2019-Ohio-868 , in which the Eighth District again referred to the actual-prejudice test set forth in Jones.

2022Cuyahoga No. 107029, 2019-Ohio-868 , in which the Eighth District again referred to the actual-prejudice test set forth in Jones.

12022–2022
State v. Walls green
ohio · 2002
1 sentence

2021“A court must ‘consider the evidence as it exists when the indictment is filed and the prejudice the defendant will suffer at trial due to the delay.’” Id., quoting Walls at ¶ 52 . {¶13} If the defendant demonstrates evidence of faded memories, unavailable witnesses or lost evidence, he might satisfy the actual-prejudice requirement.

12021–2021

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2901.13 (4) OH § Ohio Rev. Code § 2907.02 (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

OH 12 (2016–2025) MI 6 (2020–2026) GA 2 (2019–2019)

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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