claim for plain error (Ohio) · Go Syfert
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claim for plain error in Ohio

12 Ohio opinions name it 2 courts 2002–2024 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 (9)

CaseFollowedCited
State v. McAlpingreen
ohio · 2022 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024To show plain error, Knuff must demonstrate that “an error occurred, that the error was obvious, and that there is ‘a reasonable probability that the error resulted in prejudice,’ meaning that the error affected the outcome of the trial,” (emphasis added in Rogers) State v. McAlpin, 169 Ohio St.3d 279, 2022-Ohio-1567, 204 N.E.3d 459, ¶ 66, quoting State v. Rogers, 143 Ohio St.3d 385, 2015-Ohio-2459, 38 N.E.3d 860, ¶ 22. {¶ 118} Knuff cannot demonstrate error with respect to the testimony about which he now complains.

2024To show plain error, Knuff must demonstrate that “an error occurred, that the error was obvious, and that there is ‘a reasonable probability that the error resulted in prejudice,’ meaning that the error affected the outcome of the trial,” (emphasis added in Rogers) State v. McAlpin, 169 Ohio St.3d 279, 2022-Ohio-1567, 204 N.E.3d 459, ¶ 66, quoting State v. Rogers, 143 Ohio St.3d 385, 2015-Ohio-2459, 38 N.E.3d 860, ¶ 22. {¶ 118} Knuff cannot demonstrate error with respect to the testimony about which he now complains.

11
State v. Rogersgreen
ohio · 2015 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024To show plain error, Knuff must demonstrate that “an error occurred, that the error was obvious, and that there is ‘a reasonable probability that the error resulted in prejudice,’ meaning that the error affected the outcome of the trial,” (emphasis added in Rogers) State v. McAlpin, 169 Ohio St.3d 279, 2022-Ohio-1567, 204 N.E.3d 459, ¶ 66, quoting State v. Rogers, 143 Ohio St.3d 385, 2015-Ohio-2459, 38 N.E.3d 860, ¶ 22. {¶ 118} Knuff cannot demonstrate error with respect to the testimony about which he now complains.

2024To show plain error, Knuff must demonstrate that “an error occurred, that the error was obvious, and that there is ‘a reasonable probability that the error resulted in prejudice,’ meaning that the error affected the outcome of the trial,” (emphasis added in Rogers) State v. McAlpin, 169 Ohio St.3d 279, 2022-Ohio-1567, 204 N.E.3d 459, ¶ 66, quoting State v. Rogers, 143 Ohio St.3d 385, 2015-Ohio-2459, 38 N.E.3d 860, ¶ 22. {¶ 118} Knuff cannot demonstrate error with respect to the testimony about which he now complains.

11
McMaster v. Akron Health Departmentgreen
ohioctapp · 2010 · cited in 1 Ohio opinions naming this issue, 2021–2021
2 sentences

2021See Bass-Fineberg Leasing, Inc., 2015-Ohio-46, at ¶ 24 , quoting McMaster, 189 Ohio App.3d 222 , 2010-Ohio-3851 , at ¶ 20.

2021See Bass-Fineberg Leasing, Inc., 2015-Ohio-46, at ¶ 24 , quoting McMaster, 189 Ohio App.3d 222 , 2010-Ohio-3851 , at ¶ 20. {¶67} Lastly, Father cites to R.C. 3119.30(B)(1) and argues that the trial court failed to perform the proper analysis regarding the rebuttable presumption that Mother, as the child support obligee, is to provide health insurance.

11
Bass-Fineberg Leasing, Inc. v. Modern Auto Sales, Inc.green
ohioctapp · 2015 · cited in 1 Ohio opinions naming this issue, 2021–2021
2 sentences

2021See Bass-Fineberg Leasing, Inc., 2015-Ohio-46, at ¶ 24 , quoting McMaster, 189 Ohio App.3d 222 , 2010-Ohio-3851 , at ¶ 20.

2021See Bass-Fineberg Leasing, Inc., 2015-Ohio-46, at ¶ 24 , quoting McMaster, 189 Ohio App.3d 222 , 2010-Ohio-3851 , at ¶ 20. {¶67} Lastly, Father cites to R.C. 3119.30(B)(1) and argues that the trial court failed to perform the proper analysis regarding the rebuttable presumption that Mother, as the child support obligee, is to provide health insurance.

11
Payne v. Tennesseegreen
scotus · 1991 · cited in 1 Ohio opinions naming this issue, 2016–2016
2 sentences

2016See State v. Cunningham, 105 Ohio St.3d 197 , 2004-Ohio-7007 , 824 N.E.2d 504 , ¶ 89. {¶ 101} The United States Supreme Court has described victim-impact testimony in a capital case as “evidence relating to the personal characteristics of the victim and the emotional impact of the crimes on the victim’s family.” Payne v. Tennessee, 501 U.S. 808, 817 , 111 S.Ct. 2597 , 115 L.Ed.2d 720 (1991).

2016See State v. Cunningham, 105 Ohio St.3d 197 , 2004-Ohio-7007 , 824 N.E.2d 504 , ¶ 89. {¶ 101} The United States Supreme Court has described victim-impact testimony in a capital case as “evidence relating to the personal characteristics of the victim and the emotional impact of the crimes on the victim’s family.” Payne v. Tennessee, 501 U.S. 808, 817 , 111 S.Ct. 2597 , 115 L.Ed.2d 720 (1991).

11
State v. Woodsgreen
ohioctapp · 1982 · cited in 1 Ohio opinions naming this issue, 2016–2016
2 sentences

2016See State v. Woods, 8 Ohio App.3d 56, 61 , 455 N.E.2d 1289 (8th Dist.1982) (defendant cannot be excluded from testimonial proceedings where defendant’s knowledge might assist counsel). {¶35} In light of the above, the second assignment of error is overruled. {¶36} In the third assignment of error, Shropshire claims that it was improper for the trial court to discuss the jury’s verdict with the jury before the court rendered its own verdict on the weapons charge.1 {¶37} We again review this claim for plain error because Shropshire did not object to the trial court’s action.

2016See State v. Woods, 8 Ohio App.3d 56, 61 , 455 N.E.2d 1289 (8th Dist.1982) (defendant cannot be excluded from testimonial proceedings where defendant’s knowledge might assist counsel). {¶35} In light of the above, the second assignment of error is overruled. {¶36} In the third assignment of error, Shropshire claims that it was improper for the trial court to discuss the jury’s verdict with the jury before the court rendered its own verdict on the weapons charge.1 {¶37} We again review this claim for plain error because Shropshire did not object to the trial court’s action.

11
State v. Cunninghamgreen
ohio · 2004 · cited in 1 Ohio opinions naming this issue, 2016–2016
2 sentences

2016See State v. Cunningham, 105 Ohio St.3d 197 , 2004-Ohio-7007 , 824 N.E.2d 504 , ¶ 89. {¶ 101} The United States Supreme Court has described victim-impact testimony in a capital case as “evidence relating to the personal characteristics of the victim and the emotional impact of the crimes on the victim’s family.” Payne v. Tennessee, 501 U.S. 808, 817 , 111 S.Ct. 2597 , 115 L.Ed.2d 720 (1991).

2016See State v. Cunningham, 105 Ohio St.3d 197 , 2004-Ohio-7007 , 824 N.E.2d 504 , ¶ 89. {¶ 101} The United States Supreme Court has described victim-impact testimony in a capital case as “evidence relating to the personal characteristics of the victim and the emotional impact of the crimes on the victim’s family.” Payne v. Tennessee, 501 U.S. 808, 817 , 111 S.Ct. 2597 , 115 L.Ed.2d 720 (1991).

11
State v. Trimblegreen
ohio · 2009 · cited in 1 Ohio opinions naming this issue, 2014–2014
2 sentences

2014See State v. Trimble, 122 Ohio St.3d 297 , 2009-Ohio-2961 , 911 N.E.2d 242, ¶ 61 (reviewing change-of-venue claim for plain error when defendant had waived the argument).

2014See State v. Trimble, 122 Ohio St.3d 297 , 2009-Ohio-2961 , 911 N.E.2d 242, ¶ 61 (reviewing change-of-venue claim for plain error when defendant had waived the argument).

11
State v. Kiddergreen
ohio · 1987 · cited in 1 Ohio opinions naming this issue, 2002–2002
1 sentence

2002See Kidder , supra. Accordingly, we overrule this assignment of error. {¶ 95} The tenth assignment of error states: {¶ 96} "DEFENDANT WAS DENIED DUE PROCESS OF LAW WHEN HE WAS ALLOWED TO BE CONVICTED FOR THE INTERVENING ACT OF ANOTHER." {¶ 97} Jones complains that in giving the following instruction on intervening cause, the court effectively amended the statute and the indictment: {¶ 98} "The defendants are responsible for the natural consequences of the defendants' unlawful act or failure to act even though the physical harm to Warren Culbreath was also caused by an intervening act or failur

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 (8)

CaseCitedYears
State v. Mammone (Slip Opinion) green
ohio · 2014
2 sentences

2023To prevail on plain-error review, [the defendant] must establish both that misconduct occurred and that but for the misconduct, the outcome of the trial clearly would have been otherwise.” (Citations omitted.) State v. Mammone, 139 Ohio St.3d 467 , 2014-Ohio-1942 , 13 N.E.3d 1051, ¶ 111 .

2023To prevail on plain-error review, [the defendant] must establish both that misconduct occurred and that but for the misconduct, the outcome of the trial clearly would have been otherwise.” (Citations omitted.) State v. Mammone, 139 Ohio St.3d 467 , 2014-Ohio-1942 , 13 N.E.3d 1051, ¶ 111 .

22016–2023
State v. Loza green
ohio · 1994
2 sentences

2023Greene No. 2007-CA-51, 2008-Ohio- 2900, ¶ 42, citing State v. Loza, 71 Ohio St.3d 61, 78 , 641 N.E.2d 1082 (1994). {¶ 32} “If a defendant failed to object to the alleged misconduct below, however, we review the claim for plain error.

2023Greene No. 2007-CA-51, 2008-Ohio- 2900, ¶ 42, citing State v. Loza, 71 Ohio St.3d 61, 78 , 641 N.E.2d 1082 (1994). {¶ 32} “If a defendant failed to object to the alleged misconduct below, however, we review the claim for plain error.

12023–2023
State v. Jones (Slip Opinion) green
ohio · 2020
2 sentences

2022Ohio’s criminal law distinguishes between errors that are objected to by a defendant at trial and those that are not; “[w]hen the defendant forfeits the right to assert an error on appeal by failing to bring it to the trial court’s attention in the first instance, an appellate court applies plain-error review.” State v. Jones, 160 Ohio St.3d 314 , 2020-Ohio-3051 , 156 N.E.3d 872, ¶ 17 ; Crim.R. 52.

2022Ohio’s criminal law distinguishes between errors that are objected to by a defendant at trial and those that are not; “[w]hen the defendant forfeits the right to assert an error on appeal by failing to bring it to the trial court’s attention in the first instance, an appellate court applies plain-error review.” State v. Jones, 160 Ohio St.3d 314 , 2020-Ohio-3051 , 156 N.E.3d 872, ¶ 17 ; Crim.R. 52.

12022–2022
Donnelly v. DeChristoforo green
scotus · 1974
2 sentences

2016State v. Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 154. *190 {¶ 125} When evaluating a prosecutorial-misconduct claim, the relevant question is whether the prosecutor’s conduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process.” Donnelly v. DeChristoforo, 416 U.S. 637, 643 , 94 S.Ct. 1868 , 40 L.Ed.2d 431 (1974).

2016State v. Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 154. *190 {¶ 125} When evaluating a prosecutorial-misconduct claim, the relevant question is whether the prosecutor’s conduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process.” Donnelly v. DeChristoforo, 416 U.S. 637, 643 , 94 S.Ct. 1868 , 40 L.Ed.2d 431 (1974).

12016–2016
State v. Lott green
ohio · 1990
2 sentences

2016Lott, 51 Ohio St.3d at 164 , 555 N.E.2d 293 . {¶ 71} Count 6 of the indictment alleged that Spaulding committed domestic violence against Singleton on December 15, 2011.

2016Lott, 51 Ohio St.3d at 164 , 555 N.E.2d 293 . {¶ 71} Count 6 of the indictment alleged that Spaulding committed domestic violence against Singleton on December 15, 2011.

12016–2016
State v. Boston green
ohio · 1989
2 sentences

2016State v. Boston, 46 Ohio St.3d 108, 128 , 545 N.E.2d 1220 (1989). “[I]n our system of justice it is the fact finder, not the so-called expert or lay witnesses, who bears the burden of assessing the credibility and veracity of witnesses.” State v. Pizzillo, 7th Dist.

2016State v. Boston, 46 Ohio St.3d 108, 128 , 545 N.E.2d 1220 (1989). “[I]n our system of justice it is the fact finder, not the so-called expert or lay witnesses, who bears the burden of assessing the credibility and veracity of witnesses.” State v. Pizzillo, 7th Dist.

12016–2016
State v. Diar green
ohio · 2008
2 sentences

2016State v. Diar, 120 Ohio St.3d 460 , 2008-Ohio-6266 , 900 N.E.2d 565, ¶ 70 . b.

2016State v. Diar, 120 Ohio St.3d 460 , 2008-Ohio-6266 , 900 N.E.2d 565, ¶ 70 . b.

12016–2016
State v. Lang green
ohio · 2011
2 sentences

2016State v. Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 154. *190 {¶ 125} When evaluating a prosecutorial-misconduct claim, the relevant question is whether the prosecutor’s conduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process.” Donnelly v. DeChristoforo, 416 U.S. 637, 643 , 94 S.Ct. 1868 , 40 L.Ed.2d 431 (1974).

2016State v. Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 154. *190 {¶ 125} When evaluating a prosecutorial-misconduct claim, the relevant question is whether the prosecutor’s conduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process.” Donnelly v. DeChristoforo, 416 U.S. 637, 643 , 94 S.Ct. 1868 , 40 L.Ed.2d 431 (1974).

12016–2016

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.01 (5) OH § Ohio Rev. Code § 2929.04 (5) OH § Ohio Rev. Code § 2929.05 (5) OH § Ohio Rev. Code § 2929.03 (4) OH § Ohio Rev. Code § 2905.01 (3) OH § Ohio Rev. Code § 2911.01 (3) OH § Ohio Rev. Code § 2911.11 (3) OH § Ohio Rev. Code § 2923.02 (3) OH § Ohio Rev. Code § 2923.13 (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

MO 70 (1990–2025) MI 37 (2001–2025) GA 35 (2011–2026) OK 28 (1998–2026) DE 21 (2014–2026) AL 16 (1999–2017) IL 15 (2008–2025) DC 13 (2001–2022) OH 12 (2002–2024) CO 8 (2007–2026) MN 6 (2015–2024) UT 6 (2008–2020) WY 4 (1994–2013) VT 4 (2004–2017) NV 3 (2015–2026) MD 2 (2012–2015) NE 2 (2019–2025) NC 2 (2007–2019) OR 2 (2025–2025)

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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