transferred intent is firmly rooted doctrine (Ohio) · Go Syfert
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transferred intent is firmly rooted doctrine in Ohio

12 Ohio opinions name it 2 courts 1992–2026 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.

Followed or applied (5)

CaseFollowedCited
State v. Sowellgreen
ohio · 1988 · cited in 12 Ohio opinions naming this issue, 1992–2026
2 sentences

2026Bradley argues that the trial court’s omission of a transferred-self-defense instruction was a plain error because that doctrine has been recognized and applied in Ohio for over 50 years. {¶ 20} To be sure, “the doctrine of transferred intent is firmly rooted in Ohio law.” State v. Sowell, 39 Ohio St.3d 322, 332 (1988).

2023State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 136 (stating "[t]he doctrine of transferred intent is firmly rooted in Ohio law," and noting transferred intent applies in aggravated murder cases); State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 ; State v. Sowell, 39 Ohio St.3d 322, 331 (1988) (rejecting the defendant's argument that his indictment was defective for alleging prior calculation and design where the defendant admitted to having a prior calculation and design to kill one person but "[i]n his attempt to carry out his design, [the defendant] purposely and intentiona

612
State v. Solomongreen
ohio · 1981 · cited in 9 Ohio opinions naming this issue, 1992–2026
2 sentences

2023State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 136 (stating "[t]he doctrine of transferred intent is firmly rooted in Ohio law," and noting transferred intent applies in aggravated murder cases); State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 ; State v. Sowell, 39 Ohio St.3d 322, 331 (1988) (rejecting the defendant's argument that his indictment was defective for alleging prior calculation and design where the defendant admitted to having a prior calculation and design to kill one person but "[i]n his attempt to carry out his design, [the defendant] purposely and intentiona

2018See R.C. 2929.04(A)(5) (“the offense at bar was part of a course of conduct involving the purposeful killing of or attempt to kill two or more persons by the offender”). {¶ 113} “The doctrine of transferred intent is firmly rooted in Ohio law.” State v. Sowell, 39 Ohio St. 3d 322 , 332, 530 N.E.2d 1294 (1988). “ ‘If one purposely causes the death of another and the death is the result of a scheme designed to implement the calculated decision to kill someone other than the victim, the offender is guilty of aggravated murder in violation of R.C. 2903.01(A).’ ” Powell, 132 Ohio St. 3d 233 , 2012-

39
State v. Powellgreen
ohio · 2012 · cited in 5 Ohio opinions naming this issue, 2015–2023
2 sentences

2023State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 136 (stating "[t]he doctrine of transferred intent is firmly rooted in Ohio law," and noting transferred intent applies in aggravated murder cases); State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 ; State v. Sowell, 39 Ohio St.3d 322, 331 (1988) (rejecting the defendant's argument that his indictment was defective for alleging prior calculation and design where the defendant admitted to having a prior calculation and design to kill one person but "[i]n his attempt to carry out his design, [the defendant] purposely and intentiona

2023State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 136 (stating "[t]he doctrine of transferred intent is firmly rooted in Ohio law," and noting transferred intent applies in aggravated murder cases); State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 ; State v. Sowell, 39 Ohio St.3d 322, 331 (1988) (rejecting the defendant's argument that his indictment was defective for alleging prior calculation and design where the defendant admitted to having a prior calculation and design to kill one person but "[i]n his attempt to carry out his design, [the defendant] purposely and intentiona

25
State v. Dean (Slip Opinion)green
ohio · 2015 · cited in 3 Ohio opinions naming this issue, 2016–2023
2 sentences

2023State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 136 (stating "[t]he doctrine of transferred intent is firmly rooted in Ohio law," and noting transferred intent applies in aggravated murder cases); State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 ; State v. Sowell, 39 Ohio St.3d 322, 331 (1988) (rejecting the defendant's argument that his indictment was defective for alleging prior calculation and design where the defendant admitted to having a prior calculation and design to kill one person but "[i]n his attempt to carry out his design, [the defendant] purposely and intentiona

2023State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 136 (stating "[t]he doctrine of transferred intent is firmly rooted in Ohio law," and noting transferred intent applies in aggravated murder cases); State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 ; State v. Sowell, 39 Ohio St.3d 322, 331 (1988) (rejecting the defendant's argument that his indictment was defective for alleging prior calculation and design where the defendant admitted to having a prior calculation and design to kill one person but "[i]n his attempt to carry out his design, [the defendant] purposely and intentiona

23
Bradshaw v. Richeygreen
scotus · 2005 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019See also Bradshaw v. Richey, 546 U.S. 74, 76 , 126 S.Ct. 602 (2005). “‘“If one purposely causes the death of another and the death is the result of a scheme designed to implement the calculated decision to kill someone other than the victim, the offender is guilty of aggravated murder in violation of R.C. 2903.01(A).”’” Dean at ¶ 136 , quoting State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 , quoting State v. Solomon, 66 Ohio St.2d 214 (1981), paragraph one of the syllabus.

2019See also Bradshaw v. Richey, 546 U.S. 74, 76 , 126 S.Ct. 602 (2005). “‘“If one purposely causes the death of another and the death is the result of a scheme designed to implement the calculated decision to kill someone other than the victim, the offender is guilty of aggravated murder in violation of R.C. 2903.01(A).”’” Dean at ¶ 136 , quoting State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 171 , quoting State v. Solomon, 66 Ohio St.2d 214 (1981), paragraph one of the syllabus.

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 (3)

CaseCitedYears
State v. Wilson green
ohioctapp · 2017
1 sentence

2019Furthermore, this evidence is sufficient evidence that Sheldon acted with prior calculation and design as to G.N.S. -17- Accord State v. Dean, 146 Ohio St.3d 106 , 2015-Ohio-4347, ¶ 147 ; State v. Wilson, 8th Dist. Cuyahoga No. 104333, 2017-Ohio-2980, ¶ 65 . “‘The doctrine of transferred intent is firmly rooted in Ohio law.’” Dean at ¶ 136, quoting State v. Sowell, 39 Ohio St.3d 322, 332 (1988).

12019–2019
People v. Bland green
cal · 2002
2 sentences

2015Summit No. 26360, 2012-Ohio-4250 , 2012 WL 4100411 , ¶ 6. {¶ 136} “The doctrine of transferred intent is firmly rooted in Ohio law.” State v. Sowell, 39 Ohio St.3d 322, 332 , 530 N.E.2d 1294 (1988). “ ‘If one purposely causes the death of another and the death is the result of a scheme designed to implement the calculated decision to kill someone other than the victim, the offender is guilty of aggravated murder in violation of R.C. 2903.01(A).’ ” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 171, quoting State v. Solomon, 66 Ohio St.2d 214 , 421 N.E.2d 139 (1981),

2015Summit No. 26360, 2012-Ohio-4250 , 2012 WL 4100411 , ¶ 6. {¶ 136} “The doctrine of transferred intent is firmly rooted in Ohio law.” State v. Sowell, 39 Ohio St.3d 322, 332 , 530 N.E.2d 1294 (1988). “ ‘If one purposely causes the death of another and the death is the result of a scheme designed to implement the calculated decision to kill someone other than the victim, the offender is guilty of aggravated murder in violation of R.C. 2903.01(A).’ ” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 171, quoting State v. Solomon, 66 Ohio St.2d 214 , 421 N.E.2d 139 (1981),

12015–2015
State v. Cook neutral
ohioctapp · 2012
1 sentence

2015Summit No. 26360, 2012-Ohio-4250 , 2012 WL 4100411 , ¶ 6. {¶ 136} “The doctrine of transferred intent is firmly rooted in Ohio law.” State v. Sowell, 39 Ohio St.3d 322, 332 , 530 N.E.2d 1294 (1988). “ ‘If one purposely causes the death of another and the death is the result of a scheme designed to implement the calculated decision to kill someone other than the victim, the offender is guilty of aggravated murder in violation of R.C. 2903.01(A).’ ” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 171, quoting State v. Solomon, 66 Ohio St.2d 214 , 421 N.E.2d 139 (1981),

12015–2015

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.01 (7) OH § Ohio Rev. Code § 2929.04 (5) OH § Ohio Rev. Code § 2929.05 (5) OH § Ohio Rev. Code § 2901.22 (4) OH § Ohio Rev. Code § 2941.25 (4) OH § Ohio Rev. Code § 2901.01 (3) OH § Ohio Rev. Code § 2903.02 (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

OH 12 (1992–2026) OK 2 (2018–2018)

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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