79 Ohio opinions name it 2 courts 1986–2026 27 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. Johnsongreen2 sentences2024Plea and Sentencing, p. 26. {¶19} “A trial court's proportionality analysis ‘does not occur in a vacuum, but, instead, focuses upon the defendant's current conduct and whether this conduct, in conjunction with the defendant's past conduct, allows a finding that consecutive service 8 Case No. 2024-T-0034 is not disproportionate [to the danger the defendant poses to the public].’ (Citations omitted.) State v. Johnson, 2023-Ohio-2008, ¶ 35 (6th Dist.).” Campbell, 2023-Ohio-4597, at ¶ 15 (11th Dist.). 2023Thus, the record’s silence on this point is not dispositive. {¶ 25} A trial court’s proportionality analysis “does not occur in a vacuum, but, instead, focuses upon the defendant’s current conduct and whether this conduct, in conjunction with the defendant’s past conduct, allows a finding that consecutive service is not disproportionate [to the seriousness of the defendant’s conduct and to the danger the defendant poses to the public].” (Brackets sic and internal quotations omitted.) State v. Johnson, 2023-Ohio-2008 , --- N.E.3d ----, ¶ 35 (6th Dist.). | 3 | 4 |
Solem v. Helmred2 sentences2020“In an as-applied challenge, the challenger ‘contends that application of the statute in the particular context in which he has acted, or in which he proposes to act, [is] unconstitutional.’” (Alteration sic.) Id., quoting Ada v. Guam Soc. of Obstetricians & Gynecologists, 506 U.S. 1011 , 1011 (1992) (Scalia, J., dissenting). {¶20} In support of his assignment of error, Mr. McCormick relies upon the United States Supreme Court’s decision in Solem v. Helm, which stated that: a court’s proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the g 2012The United States Supreme Court has held that “a court’s proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions.” Solem v. Helm, 463 U.S. 277, 292 , 103 S.Ct. 3001 , 77 L.Ed.2d 637 (1983). | 2 | 11 |
State v. Dixongreen2 sentences2022Franklin No. 17AP-884, 2018-Ohio-3759, ¶ 10 (finding the trial court engaged in a proportionality analysis even though it did not use the statutory language). {¶22} Additionally, the trial court did not specifically state that Smith’s “history of criminal conduct” demonstrates that consecutive sentences are necessary to protect the public from future crime by Smith. 2019No. 17AP-884, 2018-Ohio-3759, ¶ 10 (noting that when a court states "no single sentence can satisfy that course of conduct," the trial court has weighed the severity of consecutive sentences against the seriousness of the conduct, and this language thus "demonstrates that the trial court engaged in a proportionality analysis even though it did not use the statutory language"); State v. Nos. 18AP-935, 18AP-936, and 18AP-938 13 Cardwell, 10th Dist. | 2 | 3 |
State v. Cozzonegreen2 sentences2025However, “[t]he trial court has no obligation . . . to engage in a ‘word- for-word recitation’ of the language in the statute or to set forth its reasons to support its findings, as long as they are discernible in the record.” (Citation omitted.) State v. Cozzone, 2018-Ohio-2249, ¶ 27 (11th Dist.). {¶27} This court, as well as other appellate districts, have found the proportionality requirement satisfied where the lower court did not specifically reference the danger the offender poses to the public but otherwise demonstrated that it considered proportionality 11 Case No. 2024-T-0091 through 2025However, “[t]he trial court has no obligation . . . to engage in a ‘word-for-word recitation’ of the language in the statute or to set forth its reasons to support its findings, as long as they are discernible in the record.” (Citation omitted.) State v. Cozzone, 2018-Ohio-2249, ¶ 27 (11th Dist.). {¶47} “This court . . . ha[s] found the proportionality requirement satisfied where the lower court did not specifically reference the danger the offender poses to the public but otherwise demonstrated that it considered proportionality through examination of facts PAGE 16 OF 22 Case No. 2024-T-0094 | 2 | 2 |
State v. Campbellgreen2 sentences2025However, “[t]he trial court has no obligation . . . to engage in a ‘word-for-word recitation’ of the language in the statute or to set forth its reasons to support its findings, as long as they are discernible in the record.” (Citation omitted.) State v. Cozzone, 2018-Ohio-2249, ¶ 27 (11th Dist.). {¶47} “This court . . . ha[s] found the proportionality requirement satisfied where the lower court did not specifically reference the danger the offender poses to the public but otherwise demonstrated that it considered proportionality through examination of facts PAGE 16 OF 22 Case No. 2024-T-0094 2024Plea and Sentencing, p. 26. {¶19} “A trial court's proportionality analysis ‘does not occur in a vacuum, but, instead, focuses upon the defendant's current conduct and whether this conduct, in conjunction with the defendant's past conduct, allows a finding that consecutive service 8 Case No. 2024-T-0034 is not disproportionate [to the danger the defendant poses to the public].’ (Citations omitted.) State v. Johnson, 2023-Ohio-2008, ¶ 35 (6th Dist.).” Campbell, 2023-Ohio-4597, at ¶ 15 (11th Dist.). | 2 | 2 |
State v. Volzgreen2 sentences2024Clermont No. CA2022-06-028, 2022-Ohio-4134, ¶ 13 (consecutive sentences contrary to law where the trial court did not make the proportionality finding mandated by R.C. 2929.14[C][4]). 2023Clermont No. CA2022-06-028, 2022-Ohio-4134, ¶ 13 (consecutive sentences contrary to law where the trial court did not make the proportionality finding mandated by R.C. 2929.14[C][4]). {¶ 38} We therefore vacate that portion of the trial court's judgment imposing consecutive sentences and remand this matter to the trial court for resentencing. | 2 | 2 |
Commonwealth v. Okorogreen2 sentences2024Garner was 17 years old when he was sentenced; he will be eligible for parole and release in his early 30’s, likely ensuring him decades of “fulfillment outside the prison walls.” See also State v. Brown, 300 Kan. 542, 564 (2014) (By permitting parole after the mandatory 20-year minimum term is served, sentence gives juvenile offender a meaningful opportunity to obtain release); Commonwealth v. Okoro, 471 Mass. 51, 59 (2015) (“We do not read Miller . . . to indicate that the proportionality principle at the core of the Eighth Amendment would bar a -12- Case No. 1-23-60 mandatory sentence of li 2017Rather, in line with the concerns expressed in Graham, it gives the offender a “ ‘meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation’ ” by permitting parole after the mandatory 20-year minimum prison term is served), quoting Graham, 560 U.S. at 75 , 130 S.Ct. 2011 , 176 L.Ed.2d 825 ; Ouk v. Minnesota, 847 N.W.2d 698, 701 (Minn.2014) (“a mandatory sentence of life imprisonment with the possibility of release after 30 years is not encompassed within the rule in Miller * * * because it does not require the imposition of the harshest term of imprisonment: li | 2 | 2 |
Harmelin v. Michigangreen2 sentences2013In Harmelin v. Michigan (1991), 501 U.S. 957 , 111 S.Ct. 2680 , 115 L.Ed.2d 836 , a plurality of the Supreme Court focused the proportionality requirement set forth in Solem and eliminated the need for comparative proportionality analysis in every case. 2013In Harmelin v. Michigan (1991), 501 U.S. 957 , 111 S.Ct. 2680 , 115 L.Ed.2d 836 , a plurality of the Supreme Court focused the proportionality requirement set forth in Solem and eliminated the need for comparative proportionality analysis in every case. | 1 | 6 |
State v. Ziepfelgreen2 sentences2022State v. Ziepfel, 107 Ohio App.3d 646 , 652, 669 N.E.2d 299 (1st Dist.1995). {¶ 110} Also important to the proportionality analysis is how the state categorizes O’Malley’s offense. 2022State v. Ziepfel, 107 Ohio App.3d 646 , 652, 669 N.E.2d 299 (1st Dist.1995). {¶ 110} Also important to the proportionality analysis is how the state categorizes O’Malley’s offense. | 1 | 2 |
State v. Hillgreen2 sentences2022Therefore, in accord with our decision in Hill, 70 Ohio St.3d at 34, 635 N.E.2d 29 SUPREME COURT OF OHIO 1248, we may consider the harm caused or threatened to society in evaluating the magnitude of the offense. {¶ 89} Eighth Amendment history also supports the assertion that an actual or threatened wrong to society could be considered harm and be penalized by a fine. 2022Therefore, in accord with our decision in Hill, 70 Ohio St.3d at 34 , 635 N.E.2d 29 SUPREME COURT OF OHIO 1248, we may consider the harm caused or threatened to society in evaluating the magnitude of the offense. {¶ 89} Eighth Amendment history also supports the assertion that an actual or threatened wrong to society could be considered harm and be penalized by a fine. | 1 | 2 |
State v. Crimgreen2 sentences2021Clark No. 2018-CA-38, 2018-Ohio-4996, ¶ 11 . {¶ 81} Kelly’s criminal conduct includes a juvenile criminal history of robbery and felonious assault. 2020Clark No. 2018-CA-38, 2018-Ohio-4996, ¶11 (“A proportionality analysis, given this linkage, does not occur in a vacuum, but, instead, focuses upon the defendant’s current conduct and whether this conduct, in conjunction with the defendant’s past conduct, allows a finding that consecutive service is not disproportionate.”). | 1 | 2 |
State v. Beasleygreen2 sentences2020R.C. 2929.14(C)(4)(b); see, e.g., State v. Beasley, 153 Ohio St.3d 497 , 2018-Ohio-493, ¶ 258 (noting with disapproval that the trial judge's sentencing statements "reveal[ed] nothing about the court's proportionality analysis with respect to the [other crimes Beasley committed], and the sentences for those convictions were also ordered to be served consecutively"). 2020R.C. 2929.14(C)(4)(b); see, e.g., State v. Beasley, 153 Ohio St.3d 497 , 2018-Ohio-493, ¶ 258 (noting with disapproval that the trial judge's sentencing statements "reveal[ed] nothing about the court's proportionality analysis with respect to the [other crimes Beasley committed], and the sentences for those convictions were also ordered to be served consecutively"). | 1 | 2 |
State v. Haroldgreen2 sentences2007See State v. Harold (1996), 109 Ohio App.3d 87 , 94 . 2000State v. Harold (1996), 109 Ohio App.3d 87 . | 1 | 2 |
State v. McDonaldgreen2 sentences1995Id. at 58-60 , 31 OBR at 163-165, 509 N.E.2d at 65-67 . 1995Id. at 58-60 , 31 OBR at 163-165, 509 N.E.2d at 65-67 . | 1 | 2 |
State ex rel. Media & Democracy Ctr. v. Atty Gen.green2 sentences2026The attorney general asserted that the proportionality requirement should prohibit Armiak from turning the attorney general’s office inside out based on speculation that responsive documents relating to RAGA and RLDF must exist, even though the attorney general represented that other than his calendar, his office did not have any responsive documents. {¶ 13} The court-of-appeals magistrate granted Armiak’s motion to compel responses to the above-quoted interrogatories and requests for production of documents and expansion of the scope of the magistrate’s in camera review of documents. 2023-Ohi 2026The attorney general asserted that the proportionality requirement should prohibit Armiak from turning the attorney general’s office inside out based on speculation that responsive documents relating to RAGA and RLDF must exist, even though the attorney general represented that other than his calendar, his office did not have any responsive documents. {¶ 13} The court-of-appeals magistrate granted Armiak’s motion to compel responses to the above-quoted interrogatories and requests for production of documents and expansion of the scope of the magistrate’s in camera review of documents. 2023-Ohi | 1 | 1 |
State v. Mackgreen1 sentence2025Campbell at ¶ 14 ; State v. Mack, 2023-Ohio-4374, ¶ 82 (11th Dist.). | 1 | 1 |
State v. Schausgreen1 sentence2025State v. Schaus, 2024-Ohio-1515, ¶ 17 (6th Dist.) (Balancing the seriousness and recidivism factors in R.C. 2929.12 is not equivalent to a proportionality analysis under R.C. 2929.14(C)(4) because R.C. 2929.12 findings “relate only to individual sentences and the determination of whether the offender is more or less likely to commit future crimes.”). | 1 | 1 |
| State v. Hayesgreen | 1 | 1 |
| State v. Keaira Browngreen | 1 | 1 |
| Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc.green | 1 | 1 |
| Calero-Toledo v. Pearson Yacht Leasing Co.green | 1 | 1 |
| State v. Chaffingreen | 1 | 1 |
| State v. Barnesgreen | 1 | 1 |
| State v. Cardwellgreen | 1 | 1 |
| Kim Thul Ouk v. Stategreen | 1 | 1 |
| Bittner v. Tri-County Toyota, Inc.green | 1 | 1 |
| State v. Tuttgreen | 1 | 1 |
| United States v. Bajakajiangreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
United States Court of Appeals, Third Circuit
green
2 sentences2000In United States v. Sarbello (C.A. 3, 1993), 985 F.2d 716 , 724 , the court stated that a lower court's proportionality analysis ". . . must necessarily accommodate the facts of the case and weigh the seriousness of the offense, including the moral gravity of the crime measured in terms of the magnitude and nature of its harmful reach, against the severity of the criminal sanction. 1995It went on to state that the district court’s proportionality analysis must “‘accommodate the facts of the case and weigh the seriousness of the offense * * *.’ ” Id. at 1236-1237 , quoting United States v. Sarbello (C.A3, 1993), 985 F.2d 716 , 724. | 4 | 1994–2000 |
State v. Stevens
neutral
2 sentences2023Stark No. 2017CA00024, 2017-Ohio-8692, ¶ 10 , quoting McDougle v. Maxwell, 1 Ohio St.2d 68, 69 , 203 N.E.2d 334 (1964). {¶24} Proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions. 2022Stark No. 2017CA00024, 2017-Ohio-8692, ¶ 10 , quoting McDougle v. Maxwell, 1 Ohio St.2d 68, 69 , 203 N.E.2d 334 (1964). {¶131} Proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions. | 3 | 2018–2023 |
McDougle v. Maxwell
green
2 sentences2023Stark No. 2017CA00024, 2017-Ohio-8692, ¶ 10 , quoting McDougle v. Maxwell, 1 Ohio St.2d 68, 69 , 203 N.E.2d 334 (1964). {¶24} Proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions. 2023Stark No. 2017CA00024, 2017-Ohio-8692, ¶ 10 , quoting McDougle v. Maxwell, 1 Ohio St.2d 68, 69 , 203 N.E.2d 334 (1964). {¶24} Proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions. | 3 | 2018–2023 |
State v. Foster
green
2 sentences2011Appellant acknowledges that State v. Foster, 109 Ohio St.3d 1 , 14 2006-Ohio-856 , 845 N.E.2d 470 , held that such findings were no longer required but argues that the Foster remedy of excising sentencing sections that require findings is no longer necessary as a result of the United States Supreme Court’s decision in Oregon v. Ice (2009), 555 U.S. 160 , 129 S.Ct. 711 , 172 L.Ed.2d 517 , which held that judicial fact-finding with respect to consecutive terms of imprisonment does not violate the Sixth Amendment. 2011Appellant acknowledges that State v. Foster, 109 Ohio St.3d 1 , 14 2006-Ohio-856 , 845 N.E.2d 470 , held that such findings were no longer required but argues that the Foster remedy of excising sentencing sections that require findings is no longer necessary as a result of the United States Supreme Court’s decision in Oregon v. Ice (2009), 555 U.S. 160 , 129 S.Ct. 711 , 172 L.Ed.2d 517 , which held that judicial fact-finding with respect to consecutive terms of imprisonment does not violate the Sixth Amendment. | 3 | 2006–2011 |
State v. Mathis
green
2 sentences2008State v. Mathis , 109 Ohio St.3d 54 , 62 , 2006-Ohio-855 . {¶ 11} Under R.C. 2929.11 (B), a sentence imposed for a felony "shall be reasonably calculated to achieve the two overriding purposes of felony sentencing [protecting the public from future crime and punishing the offender] * * *, commensurate with and not demeaning to the seriousness of the offender's conduct and its impact upon the victim, and consistent with sentences imposed for similar crimes committed by similar offenders." {¶ 12} When reviewing a trial court's proportionality analysis, we review the record to determine if it dem 2008State v. Mathis , 109 Ohio St.3d 54 , 62 , 2006-Ohio-855 . {¶ 9} When reviewing a trial court's proportionality analysis, we review the record to determine if it demonstrates that the trial court failed to consider the purposes and principles of R.C. 2929.11 . | 3 | 2008–2008 |
State v. Hayes
green
2 sentences2025“R.C. 2929.14(C)(4) requires a proportionality analysis, meaning that a sentencing court must consider the aggregate term of imprisonment to be imposed because, without such consideration, there is no coherent way to evaluate whether multiple, consecutive sentences are proportional to an offender’s overall conduct for which the sentences have been imposed.” Id., quoting id. 2025“R.C. 2929.14(C)(4) requires a proportionality analysis, meaning that a sentencing court must consider the aggregate term of imprisonment to be imposed because, without such consideration, there is no coherent way to evaluate whether multiple, consecutive sentences are proportional to an offender’s overall conduct for which the sentences have been imposed.” Id., quoting id. | 2 | 2025–2025 |
State v. Glover
green
2 sentences2024Fips’s argument is misplaced. “‘A proportionality analysis considers both the defendant’s current conduct and the risk of the defendant being a danger in the future.’” State v. Hayes, 2023-Ohio-4119 , 229 N.E.3d 234, ¶ 50 (8th Dist.), quoting State v. Glover, 2023-Ohio-1153 , 212 N.E.3d 984, ¶ 26 , citing R.C. 2929.14(C)(4). “‘To make that determination, the analysis focuses upon the defendant’s current conduct and whether this conduct, in conjunction with the defendant’s past conduct, allows a finding that consecutive service is not disproportionate.’” Id., quoting Glover at ¶ 87. {¶23} The t 2024Fips’s argument is misplaced. “‘A proportionality analysis considers both the defendant’s current conduct and the risk of the defendant being a danger in the future.’” State v. Hayes, 2023-Ohio-4119 , 229 N.E.3d 234, ¶ 50 (8th Dist.), quoting State v. Glover, 2023-Ohio-1153 , 212 N.E.3d 984, ¶ 26 , citing R.C. 2929.14(C)(4). “‘To make that determination, the analysis focuses upon the defendant’s current conduct and whether this conduct, in conjunction with the defendant’s past conduct, allows a finding that consecutive service is not disproportionate.’” Id., quoting Glover at ¶ 87. {¶23} The t | 2 | 2023–2024 |
State v. Talley
neutral
2 sentences2023Trumbull No. 2021-T-0044, 2022-Ohio-1638 (“Talley I”), we found that Mr. Talley’s 3 Case No. 2021-T-0044 assignment of error lacked merit and affirmed his sentences. 2022With respect to consecutive sentences, a reviewing court “may vacate the sentence and remand the matter to the sentencing court for resentencing * * * if it clearly and convincingly finds * * * [t]hat the record does not support the sentencing 3 Case No. 2021-T-0044 court’s findings under division * * * (C)(4) of section 2929.14.” Id. | 2 | 2022–2023 |
State v. Marcum (Slip Opinion)
green
2 sentences2019“The offender’s youth at the time of the offense must still be weighed against any statutory consideration that might make an offense more serious or an offender more likely to recidivate.” State v. Long, 138 Ohio St.3d 478 , 2014-Ohio-849 , 8 N.E.3d 890, ¶ 19 . {¶ 71} “* * * [O]ur system of justice recognizes that appellate courts do have a responsibility – expressed in the proportionality principle – not to shut their eyes to grossly disproportionate sentences that are materially unjust.” (Emphasis sic.) Hutto v. Davis, 454 U.S. 370, 377 , 102 S.Ct. 703 , 70 L.Ed.2d 556 , (1982) (Powell, J., 2019“The offender’s youth at the time of the offense must still be weighed against any statutory consideration that might make an offense more serious or an offender more likely to recidivate.” State v. Long, 138 Ohio St.3d 478 , 2014-Ohio-849 , 8 N.E.3d 890, ¶ 19 . {¶ 71} “* * * [O]ur system of justice recognizes that appellate courts do have a responsibility – expressed in the proportionality principle – not to shut their eyes to grossly disproportionate sentences that are materially unjust.” (Emphasis sic.) Hutto v. Davis, 454 U.S. 370, 377 , 102 S.Ct. 703 , 70 L.Ed.2d 556 , (1982) (Powell, J., | 2 | 2018–2019 |
Hutto v. Davis
green
2 sentences2019“The offender’s youth at the time of the offense must still be weighed against any statutory consideration that might make an offense more serious or an offender more likely to recidivate.” State v. Long, 138 Ohio St.3d 478 , 2014-Ohio-849 , 8 N.E.3d 890, ¶ 19 . {¶ 71} “* * * [O]ur system of justice recognizes that appellate courts do have a responsibility – expressed in the proportionality principle – not to shut their eyes to grossly disproportionate sentences that are materially unjust.” (Emphasis sic.) Hutto v. Davis, 454 U.S. 370, 377 , 102 S.Ct. 703 , 70 L.Ed.2d 556 , (1982) (Powell, J., 2019“The offender’s youth at the time of the offense must still be weighed against any statutory consideration that might make an offense more serious or an offender more likely to recidivate.” State v. Long, 138 Ohio St.3d 478 , 2014-Ohio-849 , 8 N.E.3d 890, ¶ 19 . {¶ 71} “* * * [O]ur system of justice recognizes that appellate courts do have a responsibility – expressed in the proportionality principle – not to shut their eyes to grossly disproportionate sentences that are materially unjust.” (Emphasis sic.) Hutto v. Davis, 454 U.S. 370, 377 , 102 S.Ct. 703 , 70 L.Ed.2d 556 , (1982) (Powell, J., | 2 | 1992–2019 |
State v. Porterfield
green
2 sentences2016Cuyahoga No. 101576, 2015-Ohio-2387 , ¶ 67-68 (defendant’s claim that sentences imposed on murder and aggravated murder counts were contrary to law because trial court did not engage in a proportionality analysis was not subject to appellate review under R.C. 2953.08(D)(3)), citing State v. Porterfield, 106 Ohio St.3d 5 , 2005-Ohio-3095 , 829 N.E.2d 690, ¶ 19 . 2016Cuyahoga No. 101576, 2015-Ohio-2387 , ¶ 67-68 (defendant’s claim that sentences imposed on murder and aggravated murder counts were contrary to law because trial court did not engage in a proportionality analysis was not subject to appellate review under R.C. 2953.08(D)(3)), citing State v. Porterfield, 106 Ohio St.3d 5 , 2005-Ohio-3095 , 829 N.E.2d 690, ¶ 19 . | 2 | 2015–2016 |
State v. Walker, 89950 (5-8-2008)
neutral
2 sentences2008State v. Walker , Cuyahoga App. No. 89950, 2008-Ohio-2180 . 2008State v. Walker , Cuyahoga App. No. 89950, 2008-Ohio-2180 , at ¶ 12 , citing State v. Georgakopoulos , Cuyahoga App. No. 81934, 2003-Ohio-4341 . | 2 | 2008–2008 |
State v. Gwynne
green
1 sentence2024Accordingly, we find that the record supports the trial court’s consecutive-sentencing findings. {¶39} Further, to the extent that Rogan suggests that the trial court did not conduct a proportionality analysis, we note that in State v. Gwynne, ____ Ohio St.3d _____, 2023-Ohio-3851 , which was decided while Rogan’s case was pending, the Supreme Court of Ohio reiterated that “[a]ppellate review turns on whether the trial -22- Case No. 2-23-01 court’s findings are clearly and convincingly not supported by the record, and if the evidence supports the trial court’s consecutive-sentence findings, th | 1 | 2024–2024 |
| State v. Sprague green | 1 | 2024–2024 |
| League of Women Voters of Ohio v. Ohio Redistricting Comm. (Slip Opinion) green | 1 | 2023–2023 |
| League of Women Voters of Ohio v. Ohio Redistricting Comm. (Slip Opinion) green | 1 | 2023–2023 |
| League of Women Voters of Ohio v. Ohio Redistricting Comm. (Slip Opinion) green | 1 | 2023–2023 |
| State v. Gwynne green | 1 | 2023–2023 |
| State v. Green green | 1 | 2022–2022 |
| Timbs v. Indiana green | 1 | 2022–2022 |
| State v. Montgomery (Slip Opinion) green | 1 | 2020–2020 |
| Hollingsworth v. United States green | 1 | 2020–2020 |
| State v. Knowles neutral | 1 | 2019–2019 |
| State v. Ali green | 1 | 2019–2019 |
| State v. Long green | 1 | 2019–2019 |
| State v. Bonnell (Slip Opinion) green | 1 | 2018–2018 |
| State v. Moore green | 1 | 2018–2018 |
| Graham v. Florida green | 1 | 2017–2017 |
| Coker v. Georgia green | 1 | 2016–2016 |
| State v. Steffen green | 1 | 2016–2016 |
| State v. Forney green | 1 | 2016–2016 |
| State v. Weitbrecht green | 1 | 2014–2014 |
| State v. Williams green | 1 | 2014–2014 |
| State v. Holmes green | 1 | 2014–2014 |
| Jones v. Barnes green | 1 | 2013–2013 |
| State v. Adams green | 1 | 2013–2013 |
| State v. Hairston green | 1 | 2012–2012 |
| Oregon v. Ice green | 1 | 2011–2011 |
| State v. Powell green | 1 | 2011–2011 |
| Blakely v. Washington green | 1 | 2006–2006 |
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.