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12 Ohio opinions name it 2 courts 2002–2024 1 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. Parsongreen2 sentences2024An inquiry of a discovery violation should include three considerations referenced as the Parson factors: “(1) whether the [prosecution’s] failure to disclose was a willful violation of Crim.R. 16, (2) whether foreknowledge of the undisclosed material would have benefited the accused in the preparation of a defense, and (3) whether the accused was prejudiced.” Darmond at ¶ 35 , citing Parson, 6 Ohio St.3d 442 , 453 N.E.2d 689 , at syllabus. 2024An inquiry of a discovery violation should include three considerations referenced as the Parson factors: “(1) whether the [prosecution’s] failure to disclose was a willful violation of Crim.R. 16, (2) whether foreknowledge of the undisclosed material would have benefited the accused in the preparation of a defense, and (3) whether the accused was prejudiced.” Darmond at ¶ 35 , citing Parson, 6 Ohio St.3d 442 , 453 N.E.2d 689 , at syllabus. | 1 | 7 |
State v. Davis, 08ap-443 (3-26-2009)green2 sentences2020No. 08AP-443, 2009-Ohio-1375, ¶ 25-27 (concluding the Parson test is conjunctive requiring all three prongs to be satisfied); State v. Wiley, 10th Dist. 2020No. 08AP-443, 2009-Ohio-1375, ¶ 25-27 (concluding the Parson test is conjunctive requiring all three prongs to be satisfied); State v. Wiley, 10th Dist. | 1 | 1 |
State v. Williamsgreen2 sentences2019Franklin No. 16AP-350, 2018-Ohio-974, ¶ 22 (noting “that all three of the Parson factors must be present to demonstrate reversible error under Crim.R. 16”), citing State v. Davis, 10th Dist. 2019Franklin No. 16AP-350, 2018-Ohio-974, ¶ 22 (noting “that all three of the Parson factors must be present to demonstrate reversible error under Crim.R. 16”), citing State v. Davis, 10th Dist. | 1 | 1 |
City of Lakewood v. Papadelisgreen2 sentences2013See Lakewood, 32 Ohio St.3d at 5 , 511 N.E.2d 1138 . {¶ 37} The application of the three Parson factors to this case is unclear. 2013See Lakewood, 32 Ohio St.3d at 5 , 511 N.E.2d 1138 . {¶ 37} The application of the three Parson factors to this case is unclear. | 1 | 1 |
State v. Halegreen2 sentences2013Id. at syllabus; see also State v. Hale, 119 Ohio St.3d 118 , 2008-Ohio-3426 , 892 N.E.2d 864 . {¶25} In Darmond, the Ohio Supreme Court noted that several of the factors We, therefore, reject the state’s proposition that a trial court’s legal conclusions in a pretrial 3 motion to dismiss are subject to a de novo review on appeal. discussed in Lakewood are similar to the Parson factors. 2013Id. at syllabus; see also State v. Hale, 119 Ohio St.3d 118 , 2008-Ohio-3426 , 892 N.E.2d 864 . {¶25} In Darmond, the Ohio Supreme Court noted that several of the factors We, therefore, reject the state’s proposition that a trial court’s legal conclusions in a pretrial 3 motion to dismiss are subject to a de novo review on appeal. discussed in Lakewood are similar to the Parson factors. | 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. Darmond
green
2 sentences2014State v. Darmond, 135 Ohio St.3d 343 , –9– 2013-Ohio-966 , 986 N.E.2d 971, ¶ 35 , citing Parson at syllabus. {¶ 25} After reviewing the record, we find that the trial court did not abuse its discretion. 2014State v. Darmond, 135 Ohio St.3d 343 , –9– 2013-Ohio-966 , 986 N.E.2d 971, ¶ 35 , citing Parson at syllabus. {¶ 25} After reviewing the record, we find that the trial court did not abuse its discretion. | 2 | 2013–2014 |
State v. Joseph
green
2 sentences2002Therefore, we conclude that information concerning the deal between LCNA and the confidential informant was properly discoverable. {¶ 15} Such a prosecutorial violation is reversible only when the record demonstrates that "(1) the prosecution's failure to disclose was a willful violation of the rule, (2) foreknowledge of the information would have benefited the accused in the preparation of his defense, and (3) the accused suffered some prejudicial effect." Id. citing State v. Parson (1983), 6 Ohio St.3d 442 , 445 . {¶ 16} With respect to the first prong of the Parson test, we conclude that th 2002Therefore, we conclude that information concerning the deal between LCNA and the confidential informant was properly discoverable. {¶ 15} Such a prosecutorial violation is reversible only when the record demonstrates that "(1) the prosecution's failure to disclose was a willful violation of the rule, (2) foreknowledge of the information would have benefited the accused in the preparation of his defense, and (3) the accused suffered some prejudicial effect." Id. citing State v. Parson (1983), 6 Ohio St.3d 442 , 445 . {¶ 16} With respect to the first prong of the Parson test, we conclude that th | 2 | 2002–2002 |
Minnesota v. Dickerson
green
2 sentences2013We have reviewed the evidence presented at the suppression hearing and find that the trial court’s findings of fact are supported by competent, credible evidence in the record. {¶ 9} Parson’s motion to suppress raises search and seizure issues under the Fourth Amendment to the United States Constitution, which guarantees "[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures[.]" Searches and seizures conducted without a warrant are per se unreasonable unless they come –6– within one of the " 'few specifically establishe 2013We have reviewed the evidence presented at the suppression hearing and find that the trial court’s findings of fact are supported by competent, credible evidence in the record. {¶ 9} Parson’s motion to suppress raises search and seizure issues under the Fourth Amendment to the United States Constitution, which guarantees "[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures[.]" Searches and seizures conducted without a warrant are per se unreasonable unless they come –6– within one of the " 'few specifically establishe | 1 | 2013–2013 |
State v. Wiles
green
2 sentences2013Darmond at ¶ 41 . {¶26} In the present case, the trial court conducted the three-prong analysis set forth in State v. Wiles, 59 Ohio St.3d 71, 78-79 , 571 N.E.2d 97 (1991), which is the same as the Parson analysis. {¶27} In rendering its decision, the trial court stated its findings of fact and conclusions of law on the record. 2013Darmond at ¶ 41 . {¶26} In the present case, the trial court conducted the three-prong analysis set forth in State v. Wiles, 59 Ohio St.3d 71, 78-79 , 571 N.E.2d 97 (1991), which is the same as the Parson analysis. {¶27} In rendering its decision, the trial court stated its findings of fact and conclusions of law on the record. | 1 | 2013–2013 |
Thompson v. Louisiana
green
2 sentences2013We have reviewed the evidence presented at the suppression hearing and find that the trial court’s findings of fact are supported by competent, credible evidence in the record. {¶ 9} Parson’s motion to suppress raises search and seizure issues under the Fourth Amendment to the United States Constitution, which guarantees "[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures[.]" Searches and seizures conducted without a warrant are per se unreasonable unless they come –6– within one of the " 'few specifically establishe 2013We have reviewed the evidence presented at the suppression hearing and find that the trial court’s findings of fact are supported by competent, credible evidence in the record. {¶ 9} Parson’s motion to suppress raises search and seizure issues under the Fourth Amendment to the United States Constitution, which guarantees "[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures[.]" Searches and seizures conducted without a warrant are per se unreasonable unless they come –6– within one of the " 'few specifically establishe | 1 | 2013–2013 |
Brady v. Maryland
green
2 sentences2007Litigants and judges in future cases should approach Joseph , and other cases citing a conjunctive Parson standard, with caution." Id. at ¶ 21, citing Brady v. Maryland (1963), 373 U.S. 83 , 87 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (footnotes omitted). {¶ 22} We agree with the Eighth District on this point. 2007Litigants and judges in future cases should approach Joseph , and other cases citing a conjunctive Parson standard, with caution." Id. at ¶ 21, citing Brady v. Maryland (1963), 373 U.S. 83 , 87 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (footnotes omitted). {¶ 22} We agree with the Eighth District on this point. | 1 | 2007–2007 |
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.