85 Ohio opinions name it 2 courts 1997–2026 22 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. Williamsgreen2 sentences2020So, if we assume without deciding that Carver’s testimony meets the first two steps of the Williams analysis, we still cannot conclude that Carver’s testimony (that she sold drugs prior to the indicted-time frame for Lester) ‘is [] [unfairly] prejudicial “because the trial court instructed the jury that this evidence could not be considered to show that [Lester] acted in conformity with a character trait.”’” Jones, 2017-Ohio-4351, at ¶ 13 , quoting Wendel, 2016-Ohio-7915, at ¶ 28 , quoting Williams, 134 Ohio St.3d 521 , 2012-Ohio-5695, at ¶ 24 , (concluding “[t]he trial court’s limiting instru 2020So, if we assume without deciding that Carver’s testimony meets the first two steps of the Williams analysis, we still cannot conclude that Carver’s testimony (that she sold drugs prior to the indicted-time frame for Lester) ‘is [] [unfairly] prejudicial “because the trial court instructed the jury that this evidence could not be considered to show that [Lester] acted in conformity with a character trait.”’” Jones, 2017-Ohio-4351, at ¶ 13 , quoting Wendel, 2016-Ohio-7915, at ¶ 28 , quoting Williams, 134 Ohio St.3d 521 , 2012-Ohio-5695, at ¶ 24 , (concluding “[t]he trial court’s limiting instru | 3 | 9 |
State v. Tenchgreen2 sentences2024Thus, the testimonial evidence presented by Walters “fails the first part of the Williams test: relevance,” State v. Tench, 156 Ohio St.3d 85, 2018- Ohio-5205, 123 N.E.3d 955, ¶ 162. 38 January Term, 2024 {¶ 127} However, defense counsel did not object to Walters’s testimony at trial, and Knuff has not demonstrated the existence of a reasonable probability that any error in allowing the testimony from his sister affected the outcome of the trial. 4. 2024Thus, the testimonial evidence presented by Walters “fails the first part of the Williams test: relevance,” State v. Tench, 156 Ohio St.3d 85, 2018- Ohio-5205, 123 N.E.3d 955, ¶ 162. 38 January Term, 2024 {¶ 127} However, defense counsel did not object to Walters’s testimony at trial, and Knuff has not demonstrated the existence of a reasonable probability that any error in allowing the testimony from his sister affected the outcome of the trial. 4. | 2 | 2 |
State v. Harrisgreen2 sentences2020Harris, 2020-Ohio-805 at ¶ 19 (trial court had no duty to inquire further about conflict of interest where defendant failed to direct appellate court to a specific instance in the record demonstrating an actual conflict). 2020Harris, 2020-Ohio-805 at ¶ 19 (trial court had no duty to inquire further about conflict of interest where defendant failed to direct appellate court to a specific instance in the record demonstrating an actual conflict). | 2 | 2 |
Leiby v. Am. Title Solutions, L.L.C.green1 sentence2026Title Sols., LLC, 2024-Ohio-151, ¶ 12 (9th Dist.), quoting Citibank (South Dakota) N.A. v. Masters, 2008-Ohio-1323, ¶ 9 (9th Dist.). “‘Any claim of trial court error must be based on the actions of the trial court, not on the magistrate’s findings or proposed decision.’” Leiby at ¶ 12 , quoting Masters at ¶ 9 . {¶26} Here, the magistrate filed an order on November 18, 2024, denying Williams’ motion to dismiss. | 1 | 1 |
Citibank (South Dakota) v. Masters, 07ca0073-M (3-24-2008)green1 sentence2026Title Sols., LLC, 2024-Ohio-151, ¶ 12 (9th Dist.), quoting Citibank (South Dakota) N.A. v. Masters, 2008-Ohio-1323, ¶ 9 (9th Dist.). “‘Any claim of trial court error must be based on the actions of the trial court, not on the magistrate’s findings or proposed decision.’” Leiby at ¶ 12 , quoting Masters at ¶ 9 . {¶26} Here, the magistrate filed an order on November 18, 2024, denying Williams’ motion to dismiss. | 1 | 1 |
State v. Robertsgreen2 sentences2025State v. Roberts, 2023-Ohio-142, ¶ 39 (6th Dist.). {¶ 49} Although appellant cites other cases in which the state presented evidence of cohabitation using factors not present in this case, such as receiving mail at the same address or helping with household bills, “the state is not required to establish all the Williams factors in order to demonstrate that the defendant shared familial or financial responsibilities.” Crisp, 2023-Ohio-3537, at ¶ 41 . 2025State v. Roberts, 2023-Ohio-142, ¶ 39 (6th Dist.). {¶ 49} Although appellant cites other cases in which the state presented evidence of cohabitation using factors not present in this case, such as receiving mail at the same address or helping with household bills, “the state is not required to establish all the Williams factors in order to demonstrate that the defendant shared familial or financial responsibilities.” Crisp, 2023-Ohio-3537, at ¶ 41 . | 1 | 1 |
State v. Simbogreen1 sentence2025Clark, 2008-Ohio-3748 , at ¶ 32 (“If the trial judge completely failed to comply with the rule, . . . the plea must be vacated.”); State v. Simbo, 2023-Ohio-4404, ¶ 6-14 (9th Dist.) (sustaining the defendant’s challenge to his guilty plea because the trial court completely failed to inform the defendant that he faced a mandatory prison term); State v. Garrett, 2009-Ohio-2339 , ¶ 9-10 (9th Dist.) (same); see Sarkozy, 2008-Ohio-509 , at ¶ 22, 26. | 1 | 1 |
State v. Fishgreen1 sentence2025Evidentiary Hearing and Judgment Entry {¶ 13} The evidentiary hearing on Williams’ motion to withdraw plea was held on April 25, 2024, May 16, 2024 and July 1, 2024. 5. {¶ 14} The trial court issued its 12-page judgment entry on September 6, 2024, and set forth that in deciding whether to grant or deny a presentence motion to withdraw plea, it must consider and analyze the nine factors in State v. Fish, 104 Ohio App.3d 236 (1st Dist. 1995) (“Nine Factor Analysis”).2 The trial court also cited, inter alia, State v. Warren, 2024-Ohio-1072 (6th Dist.). {¶ 15} Based on the evidence from the eviden | 1 | 1 |
State v. Eulergreen1 sentence2025The State cites State v. Euler, 2019-Ohio-235, ¶ 6 (6th Dist.) (“Withdrawal of a plea will not be permitted merely because a defendant has experienced a change of heart.”). {¶ 36} The State observes, with respect to feeling rushed, that Williams claims he felt forced to enter the guilty plea because he only had two or three hours to make a decision. | 1 | 1 |
State v. Irishgreen1 sentence2025State v. Irish, 2019-Ohio-2765, ¶ 33 (3d Dist.), citing State v. Spencer, 2017-Ohio-456 , ¶ 34 (4th Dist.) (the State has a constitutional duty to exercise reasonable diligence to serve the indictment). {¶ 40} Third, the trial court found that Williams asserted his speedy-trial right four months after being arraigned and did not assert it sooner because he was unaware of the charges. | 1 | 1 |
Oregon v. Bradshawgreen2 sentences2024In affirming the trial court’s denial of Williams’s motion to suppress, we stated that Williams “evinced a willingness and a desire for a generalized 32 OHIO FIRST DISTRICT COURT OF APPEALS discussion about the investigation.” Id. at ¶ 36, quoting Oregon v. Bradshaw, 462 U.S. 1039, 1045-1046 , 103 S.Ct. 2830 , 77 L.Ed.2d 405 (1983). {¶90} Because Gill, even if he had invoked his right to counsel, repeatedly reinitiated a dialogue with the detectives and “evinced a willingness and a desire for a generalized discussion about the investigation,” we hold that the trial court did not err in denying 2024In affirming the trial court’s denial of Williams’s motion to suppress, we stated that Williams “evinced a willingness and a desire for a generalized 32 OHIO FIRST DISTRICT COURT OF APPEALS discussion about the investigation.” Id. at ¶ 36, quoting Oregon v. Bradshaw, 462 U.S. 1039, 1045-1046 , 103 S.Ct. 2830 , 77 L.Ed.2d 405 (1983). {¶90} Because Gill, even if he had invoked his right to counsel, repeatedly reinitiated a dialogue with the detectives and “evinced a willingness and a desire for a generalized discussion about the investigation,” we hold that the trial court did not err in denying | 1 | 1 |
State v. Perrygreen2 sentences2024See generally State v. Perry, 10 Ohio St.2d 175, 180 , 226 N.E.2d 104 (1967). {¶18} Finally, with respect to his ineffective-assistance-of-counsel claims, Williams did not present substantive grounds for relief. 2024See generally State v. Perry, 10 Ohio St.2d 175, 180 , 226 N.E.2d 104 (1967). {¶18} Finally, with respect to his ineffective-assistance-of-counsel claims, Williams did not present substantive grounds for relief. | 1 | 1 |
State v. Williamsgreen1 sentence2024Some courts consider the criminal standard for determining cohabitation, where “the essential elements . . . [are] (1) the sharing of familial or financial responsibilities and (2) consortium.” Annenberg v. Annenberg, 2015-Ohio-2115 , ¶ 16 (1st Dist.), citing State v. Williams, 79 Ohio St.3d 459, 465 (1997); see Mengel v. Mengel, 2021-Ohio- 4166, ¶ 14-16 (5th Dist.) (the court cited the Williams standard and analyzed the facts that supported a finding that the relationship rose to the level of consortium (the couple’s sexual and romantic relationship, their sharing of the master bedroom, their | 1 | 1 |
State v. Yarbroughgreen1 sentence2024Yarbrough, 95 Ohio St.3d 227 at ¶ 79, 82 ; Treesh, 90 Ohio St.3d at 485 . {¶23} Even applying the inapplicable Williams test, there was additional direct and circumstantial evidence demonstrating both a sharing of responsibilities and consortium. | 1 | 1 |
Williams v. Bur. of Workers' Comp.green1 sentence2024No. CA2013-09-006, 2014-Ohio-1889, ¶ 16 (stating that “[o]nce the applicable * * * period under R.C. 4123.52 expired, the Industrial Commission was without jurisdiction to make any further findings, awards, or orders, and Williams’ claim was deemed to have lapsed”); Chatfield v. Whirlpool Corp., 3d Dist. | 1 | 1 |
Fox v. Foxgreen1 sentence2024Some courts consider the criminal standard for determining cohabitation, where “the essential elements . . . [are] (1) the sharing of familial or financial responsibilities and (2) consortium.” Annenberg v. Annenberg, 2015-Ohio-2115 , ¶ 16 (1st Dist.), citing State v. Williams, 79 Ohio St.3d 459, 465 (1997); see Mengel v. Mengel, 2021-Ohio- 4166, ¶ 14-16 (5th Dist.) (the court cited the Williams standard and analyzed the facts that supported a finding that the relationship rose to the level of consortium (the couple’s sexual and romantic relationship, their sharing of the master bedroom, their | 1 | 1 |
| State v. Bethelgreen | 1 | 1 |
| City of Norwood v. Burtongreen | 1 | 1 |
| The Ohio National Life Insurance Company v. United Statesgreen | 1 | 1 |
| Vos v. Stategreen | 1 | 1 |
| State v. Lestergreen | 1 | 1 |
| State v. Bursongreen | 1 | 1 |
| State v. Tench (Slip Opinion)green | 1 | 1 |
| State v. Beygreen | 1 | 1 |
| State v. Snowdengreen | 1 | 1 |
| State v. Williamsgreen | 1 | 1 |
| State v. Wardgreen | 1 | 1 |
| Strickland v. Washingtongreen | 1 | 1 |
| State v. Kirkland (Slip Opinion)green | 1 | 1 |
| Colorado v. Connellygreen | 1 | 1 |
| State v. Hillgreen | 1 | 1 |
| United States v. Kellogggreen | 1 | 1 |
| State v. Wengergreen | 1 | 1 |
| State v. Clarkgreen | 1 | 1 |
| State v. Griffingreen | 1 | 1 |
| State v. Lowerygreen | 1 | 1 |
| State v. Culpgreen | 1 | 1 |
| State v. Jonesgreen | 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. Burnside
green
2 sentences2018Id. {¶ 30} In denying Williams’s motion to suppress, the trial court correctly identified that the totality of the circumstances must be considered. 2012When considering a motion to suppress, the trial court assumes the role of trier of fact and is therefore in the best position to resolve factual questions and evaluate the credibility of witnesses.’” State v. Roberts, 110 Ohio St.3d 71 , 2006-Ohio-3665 , 850 N.E.2d 1168, at ¶100 , quoting State v. Burnside, 100 Ohio St.3d 152 , 2003-Ohio-5372 , 797 N.E.2d 71, at ¶8 , citing State v. Mills (1992), 62 Ohio St.3d 357, 366 , 582 N.E.2d 972 . | 3 | 2011–2018 |
Village of Grafton v. Ohio Edison Co.
green
2 sentences2025Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 , 105 (1996). 2004Grafton v. Ohio Edison Co. (1996), 77 Ohio St.3d 102 , 105 ; Zemcik v. La Pine Truck Sales Equipment (1998), 124 Ohio App.3d 581 , 585 . | 2 | 2004–2025 |
State v. Morales
green
2 sentences2019For the evidence to be excluded on this basis, “the probative value must be minimal and the prejudice great.” State v. Morales, 32 Ohio St.3d 252, 257 , 513 N.E.2d 267 (1987). 2019For the evidence to be excluded on this basis, “the probative value must be minimal and the prejudice great.” State v. Morales, 32 Ohio St.3d 252, 257 , 513 N.E.2d 267 (1987). | 2 | 2018–2019 |
State v. Xie
green
2 sentences2018Id. at paragraph one of the syllabus. {¶8} We consider several factors when reviewing a trial court’s decision to grant or deny a defendant’s presentence motion to withdraw a plea, including: (1) whether the withdrawal will prejudice the prosecution; (2) the representation afforded to the defendant by counsel; (3) the extent of the hearing held pursuant to 1 Williams’s brief contains different versions of his assignment of error. 2010Consequently, the trial court cited State v. Xie (1992), 62 Ohio St.3d 521 , syllabus, for the propositions that “[a] defendant does not have an absolute right to withdraw a guilty plea prior to sentencing. | 2 | 2010–2018 |
Lycan v. Cleveland
green
1 sentence2026AJZ’s Hauling, L.L.C. v. Trunorth Warranty Programs of N. Am., 2023-Ohio-3097 , ¶ 16, citing Lycan v. City of Cleveland, 2022-Ohio-4676, ¶ 21 . 3 After lessees filed a notice of appeal, this court remanded the matter—at Williams’s request—for the trial court to address Williams’s motion for prejudgment interest, and the trial court entered an order “amend[ing]” the March 13, 2025 entry “solely to award [Williams] prejudgment interest from September 1, 2019 to the date of th[e] amended entry.” Lessees did not thereafter file an amended notice of appeal, and no party filed a new notice of appeal | 1 | 2026–2026 |
State v. Adams (Slip Opinion)
green
1 sentence2025The court extensively and methodically examined each claim individually. {¶ 23} With respect to the preindictment delay claim, the court found that Williams’ counsel’s (who filed the motion to withdraw) application of State v. Adams, 2015-Ohio-3954 , that “‘[a] delay becomes presumptively prejudicial as it approaches one year in length’” in connection with a preindictment delay was “an incorrect reading of Adams.” The trial court then quoted what the Adams court stated: “‘Unlike a Sixth Amendment speedy-trial claim, no presumption of prejudice arises in the due-process context when a preindict | 1 | 2025–2025 |
State v. Crisp
green
2 sentences2025State v. Roberts, 2023-Ohio-142, ¶ 39 (6th Dist.). {¶ 49} Although appellant cites other cases in which the state presented evidence of cohabitation using factors not present in this case, such as receiving mail at the same address or helping with household bills, “the state is not required to establish all the Williams factors in order to demonstrate that the defendant shared familial or financial responsibilities.” Crisp, 2023-Ohio-3537, at ¶ 41 . 2025State v. Roberts, 2023-Ohio-142, ¶ 39 (6th Dist.). {¶ 49} Although appellant cites other cases in which the state presented evidence of cohabitation using factors not present in this case, such as receiving mail at the same address or helping with household bills, “the state is not required to establish all the Williams factors in order to demonstrate that the defendant shared familial or financial responsibilities.” Crisp, 2023-Ohio-3537, at ¶ 41 . | 1 | 2025–2025 |
State v. Warren
green
1 sentence2025Evidentiary Hearing and Judgment Entry {¶ 13} The evidentiary hearing on Williams’ motion to withdraw plea was held on April 25, 2024, May 16, 2024 and July 1, 2024. 5. {¶ 14} The trial court issued its 12-page judgment entry on September 6, 2024, and set forth that in deciding whether to grant or deny a presentence motion to withdraw plea, it must consider and analyze the nine factors in State v. Fish, 104 Ohio App.3d 236 (1st Dist. 1995) (“Nine Factor Analysis”).2 The trial court also cited, inter alia, State v. Warren, 2024-Ohio-1072 (6th Dist.). {¶ 15} Based on the evidence from the eviden | 1 | 2025–2025 |
Chatfield v. Whirlpool Corp.
neutral
1 sentence2024No. 9-21-20, 2021-Ohio-4365, ¶ 15 ; Cocherl v. Ohio DOT, 10th Dist. | 1 | 2024–2024 |
State v. Reed
green
1 sentence2024Clark No. 2021-CA-59, 2022-Ohio-3461, ¶ 21 . | 1 | 2024–2024 |
State v. Treesh
green
1 sentence2024Yarbrough, 95 Ohio St.3d 227 at ¶ 79, 82 ; Treesh, 90 Ohio St.3d at 485 . {¶23} Even applying the inapplicable Williams test, there was additional direct and circumstantial evidence demonstrating both a sharing of responsibilities and consortium. | 1 | 2024–2024 |
State v. Hughbanks
green
2 sentences2024With respect to Williams’s claim asserting a due-process challenge to his bail and indictment, we note that a challenge to pretrial bail is moot following a conviction, see State v. Hughbanks, 99 Ohio St.3d 365 , 2003-Ohio-4121 , 792 N.E.2d 1081, ¶ 35 , and that a defendant may not collaterally attack his or her conviction based on a defective 6 OHIO FIRST DISTRICT COURT OF APPEALS indictment, see State v. Reed, 2d Dist. 2024With respect to Williams’s claim asserting a due-process challenge to his bail and indictment, we note that a challenge to pretrial bail is moot following a conviction, see State v. Hughbanks, 99 Ohio St.3d 365 , 2003-Ohio-4121 , 792 N.E.2d 1081, ¶ 35 , and that a defendant may not collaterally attack his or her conviction based on a defective 6 OHIO FIRST DISTRICT COURT OF APPEALS indictment, see State v. Reed, 2d Dist. | 1 | 2024–2024 |
Smith v. Sheldon (Slip Opinion)
green
1 sentence2024See Article IV, Section 4(A), Ohio Constitution; R.C. 2931.03; State v. Harper, 160 Ohio St.3d 480 , 2020-Ohio-2913 , 159 N.E.3d 248, ¶ 25 , quoting Smith v. Sheldon, 157 Ohio St.3d 1 , 2019-Ohio-1677 , 131 N.E.3d 1 , ¶ 8 (“[A] common pleas court has subject-matter jurisdiction over felony cases.”). {¶15} The first, second, third, and fifth assignments of error are overruled. 5 OHIO FIRST DISTRICT COURT OF APPEALS 2017 Petition Properly Denied {¶16} In his fourth assignment of error, Williams contends that “the trial court abused its discretion when it did not * * * make a timely judgment and | 1 | 2024–2024 |
State v. Harper (Slip Opinion)
green
2 sentences2024See Article IV, Section 4(A), Ohio Constitution; R.C. 2931.03; State v. Harper, 160 Ohio St.3d 480 , 2020-Ohio-2913 , 159 N.E.3d 248, ¶ 25 , quoting Smith v. Sheldon, 157 Ohio St.3d 1 , 2019-Ohio-1677 , 131 N.E.3d 1 , ¶ 8 (“[A] common pleas court has subject-matter jurisdiction over felony cases.”). {¶15} The first, second, third, and fifth assignments of error are overruled. 5 OHIO FIRST DISTRICT COURT OF APPEALS 2017 Petition Properly Denied {¶16} In his fourth assignment of error, Williams contends that “the trial court abused its discretion when it did not * * * make a timely judgment and 2024See Article IV, Section 4(A), Ohio Constitution; R.C. 2931.03; State v. Harper, 160 Ohio St.3d 480 , 2020-Ohio-2913 , 159 N.E.3d 248, ¶ 25 , quoting Smith v. Sheldon, 157 Ohio St.3d 1 , 2019-Ohio-1677 , 131 N.E.3d 1 , ¶ 8 (“[A] common pleas court has subject-matter jurisdiction over felony cases.”). {¶15} The first, second, third, and fifth assignments of error are overruled. 5 OHIO FIRST DISTRICT COURT OF APPEALS 2017 Petition Properly Denied {¶16} In his fourth assignment of error, Williams contends that “the trial court abused its discretion when it did not * * * make a timely judgment and | 1 | 2024–2024 |
| State v. Hough green | 1 | 2023–2023 |
| State v. Brown green | 1 | 2023–2023 |
| State v. Zeh green | 1 | 2022–2022 |
| Blakemore v. Blakemore green | 1 | 2022–2022 |
| State v. Drummond green | 1 | 2022–2022 |
| State v. Starks neutral | 1 | 2022–2022 |
| State v. Caldwell green | 1 | 2022–2022 |
| Argabrite v. Neer green | 1 | 2021–2021 |
| State v. Martin green | 1 | 2020–2020 |
| State v. Wendel green | 1 | 2020–2020 |
| State v. Jones green | 1 | 2020–2020 |
| State v. Creech (Slip Opinion) green | 1 | 2019–2019 |
| State v. Marcum (Slip Opinion) green | 1 | 2018–2018 |
| State v. Bradley green | 1 | 2017–2017 |
| LaSalle Institutional Realty Advisors, L.L.C. v. Nantucket on Montgomery Road, Ltd. green | 1 | 2017–2017 |
| State v. Simpson green | 1 | 2016–2016 |
| Penson v. Ohio green | 1 | 2015–2015 |
| State v. Starnes green | 1 | 2015–2015 |
| State v. Ceron green | 1 | 2014–2014 |
| State v. Clayton green | 1 | 2013–2013 |
| State v. Morris green | 1 | 2013–2013 |
| State v. Bush green | 1 | 2012–2012 |
| State v. Johnson green | 1 | 2012–2012 |
| State v. Brewer green | 1 | 2012–2012 |
| State v. Mills green | 1 | 2012–2012 |
| State v. Bush green | 1 | 2012–2012 |
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.
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.