12 Ohio opinions name it 3 courts 1896–2025 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 ex rel. Plain Dealer Publishing Co. v. Geauga County Court of Common Pleasgreen2 sentences2006See Plain Dealer, 90 Ohio St.3d at 86-87, 734 N.E.2d 1214 (juvenile court judge abused his discretion in closing delinquency proceeding when the movant did not introduce any evidence in support of closure); Louden, 91 Ohio St.3d at 65 , 741 N.E.2d 517 , quoting Plain Dealer, 90 Ohio St.3d at 87, 734 N.E.2d 1214 (“Judge Louden did not hear evidence and argument on the issue of closing the detention hearing and did not make the requisite findings before adjudicating the issue in an informal, off-the-record procedure. * * * In the absence of the foregoing, Judge Louden’s closure of the detention 2006See Plain Dealer, 90 Ohio St.3d at 86-87, 734 N.E.2d 1214 (juvenile court judge abused his discretion in closing delinquency proceeding when the movant did not introduce any evidence in support of closure); Louden, 91 Ohio St.3d at 65 , 741 N.E.2d 517 , quoting Plain Dealer, 90 Ohio St.3d at 87, 734 N.E.2d 1214 (“Judge Louden did not hear evidence and argument on the issue of closing the detention hearing and did not make the requisite findings before adjudicating the issue in an informal, off-the-record procedure. * * * In the absence of the foregoing, Judge Louden’s closure of the detention | 2 | 3 |
State v. Williamsgreen2 sentences2023See, e.g., Tallmadge v. McCoy, 96 Ohio App.3d 604, 610 , 645 N.E.2d 802 (9th Dist.1994) (“When an officer, after a lawful stop, observes that the driver has glassy, bloodshot eyes, a strong odor of alcohol on his breath, and is able to perform physical coordination tests only poorly, probable cause exists both for the detention for inquiry and the subsequent arrest for driving under the influence of alcohol.”), citing State v. Williams, 83 Ohio App.3d 536, 539 , 615 N.E.2d 317 (3d Dist.1992) (“When an officer, upon lawfully stopping an automobile driver, observes that the driver has glassy, bl 2023See, e.g., Tallmadge v. McCoy, 96 Ohio App.3d 604, 610 , 645 N.E.2d 802 (9th Dist.1994) (“When an officer, after a lawful stop, observes that the driver has glassy, bloodshot eyes, a strong odor of alcohol on his breath, and is able to perform physical coordination tests only poorly, probable cause exists both for the detention for inquiry and the subsequent arrest for driving under the influence of alcohol.”), citing State v. Williams, 83 Ohio App.3d 536, 539 , 615 N.E.2d 317 (3d Dist.1992) (“When an officer, upon lawfully stopping an automobile driver, observes that the driver has glassy, bl | 1 | 2 |
State ex rel. Dispatch Printing Co. v. Liasgreen2 sentences2001In the absence of the foregoing, Judge Louden’s closure of the detention hearing was unjustified and constituted “little more than [his] personal predilections.” Plain Dealer, 90 Ohio St.3d at 87 , 734 N.E.2d at 1221 ; Lias, 68 Ohio St.3d at 504 , 628 N.E.2d at 1373 (parties and those who have an interest in the cause must have an active and meaningful role in closure hearing). 2001In the absence of the foregoing, Judge Louden’s closure of the detention hearing was unjustified and constituted “little more than [his] personal predilections.” Plain Dealer, 90 Ohio St.3d at 87 , 734 N.E.2d at 1221 ; Lias, 68 Ohio St.3d at 504 , 628 N.E.2d at 1373 (parties and those who have an interest in the cause must have an active and meaningful role in closure hearing). | 1 | 2 |
State v. Farleygreen1 sentence2023Columbiana No. 95-C-9, 1996 Ohio App. LEXIS 2464 , 6-7 (June 13, 1996) (holding that there was probable cause to arrest defendant for driving while under the influence of alcohol where officer testified that he could smell a strong odor of alcohol on defendant’s breath, that defendant’s eyes were bloodshot and glassy and that the defendant failed two out of three field sobriety tests); see also State v. Farey, 2018-Ohio-1466 , 110 N.E.3d 960, ¶ 34 (5th Dist.) (it was not necessary for officer to observe poor driving performance in order to place appellant under arrest for driving under the inf | 1 | 1 |
City of Tallmadge v. McCoygreen2 sentences2023See, e.g., Tallmadge v. McCoy, 96 Ohio App.3d 604, 610 , 645 N.E.2d 802 (9th Dist.1994) (“When an officer, after a lawful stop, observes that the driver has glassy, bloodshot eyes, a strong odor of alcohol on his breath, and is able to perform physical coordination tests only poorly, probable cause exists both for the detention for inquiry and the subsequent arrest for driving under the influence of alcohol.”), citing State v. Williams, 83 Ohio App.3d 536, 539 , 615 N.E.2d 317 (3d Dist.1992) (“When an officer, upon lawfully stopping an automobile driver, observes that the driver has glassy, bl 2023See, e.g., Tallmadge v. McCoy, 96 Ohio App.3d 604, 610 , 645 N.E.2d 802 (9th Dist.1994) (“When an officer, after a lawful stop, observes that the driver has glassy, bloodshot eyes, a strong odor of alcohol on his breath, and is able to perform physical coordination tests only poorly, probable cause exists both for the detention for inquiry and the subsequent arrest for driving under the influence of alcohol.”), citing State v. Williams, 83 Ohio App.3d 536, 539 , 615 N.E.2d 317 (3d Dist.1992) (“When an officer, upon lawfully stopping an automobile driver, observes that the driver has glassy, bl | 1 | 1 |
State v. Fareygreen1 sentence2023Columbiana No. 95-C-9, 1996 Ohio App. LEXIS 2464 , 6-7 (June 13, 1996) (holding that there was probable cause to arrest defendant for driving while under the influence of alcohol where officer testified that he could smell a strong odor of alcohol on defendant’s breath, that defendant’s eyes were bloodshot and glassy and that the defendant failed two out of three field sobriety tests); see also State v. Farey, 2018-Ohio-1466 , 110 N.E.3d 960, ¶ 34 (5th Dist.) (it was not necessary for officer to observe poor driving performance in order to place appellant under arrest for driving under the inf | 1 | 1 |
Burchett v. Kiefergreen1 sentence2019Id. at 617; see also Burchett v. Kiefer, 310 F.3d 937, 944 (6th Cir.2002) (“officers act within their Summers powers when they detain an individual who approaches a property being searched pursuant to a warrant, pauses at the property line, and flees when the officers instruct him to get down”); United States v. Jennings, 544 F.3d 815 , 818–19 (7th Cir.2008) (detaining an individual who drove up and parked next to an apartment while it was being searched was “a logical extension of the rule of Summers” in order to ensure the safety of the officers engaged in the search and to protect the valid | 1 | 1 |
Ridenour v. Schwartzgreen2 sentences2001See Ridenour v. Schwartz (1994), 179 Ariz. 1, 4 , 875 P.2d 1306, 1309 . {¶ 20} Based on the foregoing, Judge Louden abused his discretion by closing the detention hearing and barring the Dispatch from the courthouse without any motion for closure, hearing on the issue, and the required findings. 2001See Ridenour v. Schwartz (1994), 179 Ariz. 1, 4 , 875 P.2d 1306, 1309 . {¶ 20} Based on the foregoing, Judge Louden abused his discretion by closing the detention hearing and barring the Dispatch from the courthouse without any motion for closure, hearing on the issue, and the required findings. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re Humphrey
green
1 sentence2025It further held that, in situations where a court determines that a money bail is “reasonably necessary,” a court must “consider the individual arrestee’s ability to pay, along with the seriousness of the charged offense and the arrestee’s criminal record, and—unless there is a valid basis for detention—set bail at a level the arrestee can reasonably afford.” Id. at 154 . 12 OHIO FIRST DISTRICT COURT OF APPEALS a right to counsel at the detention hearing. 18 U.S.C. § 3142 (f). | 1 | 2025–2025 |
Ross v. Saros
green
1 sentence2020Analysis {¶ 8} To prevail on a habeas corpus claim alleging that a trial court lacked subject-matter jurisdiction, a habeas petitioner must establish that the lack of jurisdiction was “patent and unambiguous.” Ross v. Saros, 99 Ohio St.3d 412 , 792 N.E.2d 11, ¶ 14 . {¶ 9} In proposition of law No. I, Stever argues that the court of common pleas had not acquired subject-matter jurisdiction, because he had not been placed into juvenile custody, a juvenile complaint had not been filed, and there had been no bindover hearing before his case was transferred to the court of common pleas. | 1 | 2020–2020 |
Bailey v. United States
green
2 sentences2019Id. at 617; see also Burchett v. Kiefer, 310 F.3d 937, 944 (6th Cir.2002) (“officers act within their Summers powers when they detain an individual who approaches a property being searched pursuant to a warrant, pauses at the property line, and flees when the officers instruct him to get down”); United States v. Jennings, 544 F.3d 815 , 818–19 (7th Cir.2008) (detaining an individual who drove up and parked next to an apartment while it was being searched was “a logical extension of the rule of Summers” in order to ensure the safety of the officers engaged in the search and to protect the valid 2019Id. at 617; see also Burchett v. Kiefer, 310 F.3d 937, 944 (6th Cir.2002) (“officers act within their Summers powers when they detain an individual who approaches a property being searched pursuant to a warrant, pauses at the property line, and flees when the officers instruct him to get down”); United States v. Jennings, 544 F.3d 815 , 818–19 (7th Cir.2008) (detaining an individual who drove up and parked next to an apartment while it was being searched was “a logical extension of the rule of Summers” in order to ensure the safety of the officers engaged in the search and to protect the valid | 1 | 2019–2019 |
United States v. Jennings
green
1 sentence2019Id. at 617; see also Burchett v. Kiefer, 310 F.3d 937, 944 (6th Cir.2002) (“officers act within their Summers powers when they detain an individual who approaches a property being searched pursuant to a warrant, pauses at the property line, and flees when the officers instruct him to get down”); United States v. Jennings, 544 F.3d 815 , 818–19 (7th Cir.2008) (detaining an individual who drove up and parked next to an apartment while it was being searched was “a logical extension of the rule of Summers” in order to ensure the safety of the officers engaged in the search and to protect the valid | 1 | 2019–2019 |
Disciplinary Counsel v. Medley
green
1 sentence2007But as outrageous as was the misconduct in Karto , it is exceeded in depth and scope by respondent’s improprieties. {¶ 125} More analogous is Disciplinary Counsel v. Medley, 104 Ohio St.3d 251 , 2004-Ohio-6402 , 819 N.E.2d 273 . | 1 | 2007–2007 |
State ex rel. Dispatch Printing Co. v. Louden
green
2 sentences2006See Plain Dealer, 90 Ohio St.3d at 86-87, 734 N.E.2d 1214 (juvenile court judge abused his discretion in closing delinquency proceeding when the movant did not introduce any evidence in support of closure); Louden, 91 Ohio St.3d at 65 , 741 N.E.2d 517 , quoting Plain Dealer, 90 Ohio St.3d at 87, 734 N.E.2d 1214 (“Judge Louden did not hear evidence and argument on the issue of closing the detention hearing and did not make the requisite findings before adjudicating the issue in an informal, off-the-record procedure. * * * In the absence of the foregoing, Judge Louden’s closure of the detention 2006See Plain Dealer, 90 Ohio St.3d at 86-87, 734 N.E.2d 1214 (juvenile court judge abused his discretion in closing delinquency proceeding when the movant did not introduce any evidence in support of closure); Louden, 91 Ohio St.3d at 65 , 741 N.E.2d 517 , quoting Plain Dealer, 90 Ohio St.3d at 87, 734 N.E.2d 1214 (“Judge Louden did not hear evidence and argument on the issue of closing the detention hearing and did not make the requisite findings before adjudicating the issue in an informal, off-the-record procedure. * * * In the absence of the foregoing, Judge Louden’s closure of the detention | 1 | 2006–2006 |
Illinois v. Wardlow
green
1 sentence2004Id. (noting individual's presence in a heavy drug trafficking area and his unprovoked flight upon noticing the police were sufficient to satisfy the reasonable suspicion standard). | 1 | 2004–2004 |
In Re Therklidsen
green
1 sentence2000Rather, the seventy-two hour period of limitation contained in Juv.R. 7(G) and R.C. 2151.314 is, pursuant to Therklidsen, supra., procedural only and is not mandatory. | 1 | 2000–2000 |
People v. Rulloff
neutral
1 sentence1896People v. Ruolof. 5 Park. | 1 | 1896–1896 |
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.