res judicata bars a defendant doctrine (Ohio) · Go Syfert
← Ohio issues

res judicata bars a defendant doctrine in Ohio

12 Ohio opinions name it 1 courts 2008–2025 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 (2)

CaseFollowedCited
State v. Stalnakergreen
ohioctapp · 2013 · cited in 1 Ohio opinions naming this issue, 2017–2017
1 sentence

2017Lake No. 2013-L-006, 2013-Ohio-3479, ¶12 (“the doctrine of res judicata bars a defendant from asserting the “merger” issue in a post-judgment motion for resentencing.”); State v. Holdcroft, 137 Ohio St.3d 526 , 2013- Ohio-5014, ¶8 (challenges to merger issues and consecutive sentences must be brought on direct appeal). {¶10} Appellant’s assignments of error lack merit. {¶11} For the foregoing reason, the judgment of the Lake County Court of Common Pleas is affirmed.

11
State v. Tekulvegreen
ohioctapp · 2010 · cited in 1 Ohio opinions naming this issue, 2014–2014
2 sentences

2014(Other citation omitted.) “A trial court abuses its discretion when it makes a decision that is unreasonable, unconscionable, or arbitrary.” (Citation omitted.) State v. Darmond, 135 Ohio St.3d 343 , 2013-Ohio-966 , 986 N.E.2d 971, ¶ 34 . {¶ 11} The doctrine of res judicata bars a defendant from raising matters in a post-sentence Crim.R. 32.1 motion that “ ‘ “could fairly [have] be[en] determined” in a direct appeal from his conviction, without resort to evidence outside the record.’ ” Wilson at ¶ 28, –5– quoting State v. Tekulve, 188 Ohio App.3d 792 , 2010-Ohio-3604 , 936 N.E.2d 1030, ¶ 5 (1s

2014(Other citation omitted.) “A trial court abuses its discretion when it makes a decision that is unreasonable, unconscionable, or arbitrary.” (Citation omitted.) State v. Darmond, 135 Ohio St.3d 343 , 2013-Ohio-966 , 986 N.E.2d 971, ¶ 34 . {¶ 11} The doctrine of res judicata bars a defendant from raising matters in a post-sentence Crim.R. 32.1 motion that “ ‘ “could fairly [have] be[en] determined” in a direct appeal from his conviction, without resort to evidence outside the record.’ ” Wilson at ¶ 28, –5– quoting State v. Tekulve, 188 Ohio App.3d 792 , 2010-Ohio-3604 , 936 N.E.2d 1030, ¶ 5 (1s

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 (10)

CaseCitedYears
State v. Perry green
ohio · 1967
2 sentences

2022The doctrine of res judicata bars a defendant “from raising and litigating in any proceeding, except an appeal from [a final] judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial which resulted in that judgment of conviction or on an appeal from that judgment.” State v. Perry, 10 Ohio St.2d 175, 180 , 226 N.E.2d 104 (1967).

2022The doctrine of res judicata bars a defendant “from raising and litigating in any proceeding, except an appeal from [a final] judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial which resulted in that judgment of conviction or on an appeal from that judgment.” State v. Perry, 10 Ohio St.2d 175, 180 , 226 N.E.2d 104 (1967).

52009–2022
State v. Duling green
ohio · 1970
2 sentences

2021State v. Reynolds, 79 Ohio St.3d 158, 161 , 679 N.E.2d 1131 (1997), citing State v. Duling, 21 Ohio St.2d 13 , 254 N.E.2d 670 (1970).

2021State v. Reynolds, 79 Ohio St.3d 158, 161 , 679 N.E.2d 1131 (1997), citing State v. Duling, 21 Ohio St.2d 13 , 254 N.E.2d 670 (1970).

22021–2021
State v. Reynolds green
ohio · 1997
2 sentences

2021State v. Reynolds, 79 Ohio St.3d 158, 161 , 679 N.E.2d 1131 (1997), citing State v. Duling, 21 Ohio St.2d 13 , 254 N.E.2d 670 (1970).

2021State v. Reynolds, 79 Ohio St.3d 158, 161 , 679 N.E.2d 1131 (1997), citing State v. Duling, 21 Ohio St.2d 13 , 254 N.E.2d 670 (1970).

22021–2021
State v. Woodhouse, Unpublished Decision (11-19-2004) green
ohioctapp · 2004
1 sentence

2025Id.

12025–2025
State v. Holdcroft green
ohio · 2013
1 sentence

2017Lake No. 2013-L-006, 2013-Ohio-3479, ¶12 (“the doctrine of res judicata bars a defendant from asserting the “merger” issue in a post-judgment motion for resentencing.”); State v. Holdcroft, 137 Ohio St.3d 526 , 2013- Ohio-5014, ¶8 (challenges to merger issues and consecutive sentences must be brought on direct appeal). {¶10} Appellant’s assignments of error lack merit. {¶11} For the foregoing reason, the judgment of the Lake County Court of Common Pleas is affirmed.

12017–2017
State v. Darmond green
ohio · 2013
2 sentences

2014(Other citation omitted.) “A trial court abuses its discretion when it makes a decision that is unreasonable, unconscionable, or arbitrary.” (Citation omitted.) State v. Darmond, 135 Ohio St.3d 343 , 2013-Ohio-966 , 986 N.E.2d 971, ¶ 34 . {¶ 11} The doctrine of res judicata bars a defendant from raising matters in a post-sentence Crim.R. 32.1 motion that “ ‘ “could fairly [have] be[en] determined” in a direct appeal from his conviction, without resort to evidence outside the record.’ ” Wilson at ¶ 28, –5– quoting State v. Tekulve, 188 Ohio App.3d 792 , 2010-Ohio-3604 , 936 N.E.2d 1030, ¶ 5 (1s

2014(Other citation omitted.) “A trial court abuses its discretion when it makes a decision that is unreasonable, unconscionable, or arbitrary.” (Citation omitted.) State v. Darmond, 135 Ohio St.3d 343 , 2013-Ohio-966 , 986 N.E.2d 971, ¶ 34 . {¶ 11} The doctrine of res judicata bars a defendant from raising matters in a post-sentence Crim.R. 32.1 motion that “ ‘ “could fairly [have] be[en] determined” in a direct appeal from his conviction, without resort to evidence outside the record.’ ” Wilson at ¶ 28, –5– quoting State v. Tekulve, 188 Ohio App.3d 792 , 2010-Ohio-3604 , 936 N.E.2d 1030, ¶ 5 (1s

12014–2014
Crawford v. Eastland Shopping Mall Assn. green
ohioctapp · 1983
2 sentences

2013Crawford v. Eastland Shopping Mall Assn., 11 Ohio App.3d 158 , 463 N.E.2d 655 (1983). {¶9} The doctrine of res judicata bars a defendant from making claims in a motion to withdraw a guilty plea which he could have raised on direct appeal.

2013Crawford v. Eastland Shopping Mall Assn., 11 Ohio App.3d 158 , 463 N.E.2d 655 (1983). {¶9} The doctrine of res judicata bars a defendant from making claims in a motion to withdraw a guilty plea which he could have raised on direct appeal.

12013–2013
State v. Jones, 4-07-02 (10-22-2007) green
ohioctapp · 2007
1 sentence

2009Jones , 2007-Ohio-5624 , at ¶ 1 9 , citing State v. Perry (1967), 10 Ohio St.2d 175 , 180 ; see, also, State v. Deal , 3d Dist.

12009–2009
State v. Calhoun green
ohio · 1999
1 sentence

2008State v. Calhoun , 86 Ohio St.3d 279 , 1999-Ohio-102 , at paragraph two of the syllabus. {¶ 13} Furthermore, the Supreme Court of Ohio has held that the doctrine of res judicata bars a defendant from raising any defenses or constitutional claims *Page 7 in a petition for post-conviction relief under R.C. 2953.21 that were raised or could have been raised at trial or on direct appeal.

12008–2008
State v. Calhoun green
ohio · 1999
1 sentence

2008State v. Calhoun , 86 Ohio St.3d 279 , 1999-Ohio-102 , at paragraph two of the syllabus. {¶ 13} Furthermore, the Supreme Court of Ohio has held that the doctrine of res judicata bars a defendant from raising any defenses or constitutional claims *Page 7 in a petition for post-conviction relief under R.C. 2953.21 that were raised or could have been raised at trial or on direct appeal.

12008–2008

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.02 (3) OH § Ohio Rev. Code § 2953.21 (3) OH § Ohio Rev. Code § 2953.23 (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 (2008–2025) IL 4 (2026–2026)

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.

← Caselaw search · G Cite Topics · Brief Check