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10 Ohio opinions name it 2 courts 1995–2025 3 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 |
|---|---|---|
In the Matter of Grand Jury Proceedings, (Grand Jury Empaneled June 2000 in Springfield, Illinois)green2 sentences2013Ohio Elections Comm. v. Ohio Chamber of Commerce & Citizens for a Strong Ohio, 158 Ohio App.3d 557 , 2004-Ohio-5253 , 817 N.E.2d 447 (10th Dist.), citing In re Grand Jury Proceedings (7th Cir. 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”). 2011Ohio Elections Comm. v. Ohio Chamber of Commerce & Citizens for a Strong Ohio, 158 Ohio App.3d 557 , 817 N.E.2d 447 , citing In re Grand Jury Proceedings (C.A.7, 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”). | 4 | 4 |
United States v. Bajakajiangreen2 sentences2020Mr. O’Malley further asserts that, in Bajakajian, 524 U.S. 321 , the Supreme Court “focused on the ‘proportionality’ of a forfeiture to the alleged offense, but also indicated that a person’s ‘wealth or income’ could be relevant to the Excessive Fines Clause analysis.” He argues that, taken together, 4 Timbs and Bajakajian “leave little doubt that an individual’s limited financial circumstances are not only relevant, but indispensable to a constitutional analysis.” Mr. O’Malley contends “[t]he fact that the [t]rial [c]ourt’s decision does not contain any analysis or case law concerning the mos 2020Mr. O’Malley further asserts that, in Bajakajian, 524 U.S. 321 , the Supreme Court “focused on the ‘proportionality’ of a forfeiture to the alleged offense, but also indicated that a person’s ‘wealth or income’ could be relevant to the Excessive Fines Clause analysis.” He argues that, taken together, 4 Timbs and Bajakajian “leave little doubt that an individual’s limited financial circumstances are not only relevant, but indispensable to a constitutional analysis.” Mr. O’Malley contends “[t]he fact that the [t]rial [c]ourt’s decision does not contain any analysis or case law concerning the mos | 1 | 2 |
Tyler v. Hennepin Countygreen2 sentences2025Id. at 648. 2025Id. at 648. | 1 | 1 |
United States v. James E. Bushergreen2 sentences2022Id. at 35, fn. 4. {¶ 42} Relying on two federal circuit court decisions, United States v. Sarbello, 985 F.2d 716 , 724, (3d Cir.1993), and United States v. Busher, 817 F.2d 1409 , 1415 (9th Cir.1987), fn. 10, we identified various factors that could be 13 SUPREME COURT OF OHIO considered in an excessive fines analysis: (1) “the moral gravity of the crime” and “nature of its harmful reach”; (2) “personal benefit reaped by the defendant”; (3) “the defendant’s motive and culpability”; (4) “the extent that the defendant’s interest * * * [is] tainted by [the] criminal conduct”; (5) “the dollar volu 2022Id. at 35, fn. 4 . {¶ 42} Relying on two federal circuit court decisions, United States v. Sarbello, 985 F.2d 716, 724 , (3d Cir.1993), and United States v. Busher, 817 F.2d 1409, 1415 (9th Cir.1987), fn. 10, we identified various factors that could be 13 SUPREME COURT OF OHIO considered in an excessive fines analysis: (1) “the moral gravity of the crime” and “nature of its harmful reach”; (2) “personal benefit reaped by the defendant”; (3) “the defendant’s motive and culpability”; (4) “the extent that the defendant’s interest * * * [is] tainted by [the] criminal conduct”; (5) “the dollar volu | 1 | 1 |
United States v. One Parcel of Propertygreen1 sentence1995See Shelly’s Riverside Hts., supra, 851 F.Supp. at 638 ; 11869 Westshore Dr., supra, 848 F.Supp. at 111 ; United States ex rel. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Ohio Elections Commission v. Ohio Chamber of Commerce
green
2 sentences2013Ohio Elections Comm. v. Ohio Chamber of Commerce & Citizens for a Strong Ohio, 158 Ohio App.3d 557 , 2004-Ohio-5253 , 817 N.E.2d 447 (10th Dist.), citing In re Grand Jury Proceedings (7th Cir. 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”). 2013Ohio Elections Comm. v. Ohio Chamber of Commerce & Citizens for a Strong Ohio, 158 Ohio App.3d 557 , 2004-Ohio-5253 , 817 N.E.2d 447 (10th Dist.), citing In re Grand Jury Proceedings (7th Cir. 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”). | 3 | 2011–2013 |
United States Court of Appeals, Third Circuit
green
2 sentences2022Id. at 35, fn. 4. {¶ 42} Relying on two federal circuit court decisions, United States v. Sarbello, 985 F.2d 716 , 724, (3d Cir.1993), and United States v. Busher, 817 F.2d 1409 , 1415 (9th Cir.1987), fn. 10, we identified various factors that could be 13 SUPREME COURT OF OHIO considered in an excessive fines analysis: (1) “the moral gravity of the crime” and “nature of its harmful reach”; (2) “personal benefit reaped by the defendant”; (3) “the defendant’s motive and culpability”; (4) “the extent that the defendant’s interest * * * [is] tainted by [the] criminal conduct”; (5) “the dollar volu 2022Id. at 35, fn. 4 . {¶ 42} Relying on two federal circuit court decisions, United States v. Sarbello, 985 F.2d 716, 724 , (3d Cir.1993), and United States v. Busher, 817 F.2d 1409, 1415 (9th Cir.1987), fn. 10, we identified various factors that could be 13 SUPREME COURT OF OHIO considered in an excessive fines analysis: (1) “the moral gravity of the crime” and “nature of its harmful reach”; (2) “personal benefit reaped by the defendant”; (3) “the defendant’s motive and culpability”; (4) “the extent that the defendant’s interest * * * [is] tainted by [the] criminal conduct”; (5) “the dollar volu | 1 | 2022–2022 |
State v. Hill
green
2 sentences2020Mr. O’Malley further asserts that, in Bajakajian, 524 U.S. 321 , the Supreme Court “focused on the ‘proportionality’ of a forfeiture to the alleged offense, but also indicated that a person’s ‘wealth or income’ could be relevant to the Excessive Fines Clause analysis.” He argues that, taken together, 4 Timbs and Bajakajian “leave little doubt that an individual’s limited financial circumstances are not only relevant, but indispensable to a constitutional analysis.” Mr. O’Malley contends “[t]he fact that the [t]rial [c]ourt’s decision does not contain any analysis or case law concerning the mos 2020Mr. O’Malley further asserts that, in Bajakajian, 524 U.S. 321 , the Supreme Court “focused on the ‘proportionality’ of a forfeiture to the alleged offense, but also indicated that a person’s ‘wealth or income’ could be relevant to the Excessive Fines Clause analysis.” He argues that, taken together, 4 Timbs and Bajakajian “leave little doubt that an individual’s limited financial circumstances are not only relevant, but indispensable to a constitutional analysis.” Mr. O’Malley contends “[t]he fact that the [t]rial [c]ourt’s decision does not contain any analysis or case law concerning the mos | 1 | 2020–2020 |
United States v. Louis Mongelli and Robert Mongelli
green
1 sentence2004In re Grand Jury Proceedings (C.A.7, 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”), citing United States v. Mongelli (C.A.2, 1993), 2 F.3d 29, 30 ; Spallone v. United States (1988), 487 U.S. 1251, 1257 , 109 S.Ct. 14 , 101 L.Ed.2d 964 (memorandum decision). | 1 | 2004–2004 |
Henry G. Spallone v. United States
green
2 sentences2004In re Grand Jury Proceedings (C.A.7, 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”), citing United States v. Mongelli (C.A.2, 1993), 2 F.3d 29, 30 ; Spallone v. United States (1988), 487 U.S. 1251, 1257 , 109 S.Ct. 14 , 101 L.Ed.2d 964 (memorandum decision). 2004In re Grand Jury Proceedings (C.A.7, 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”), citing United States v. Mongelli (C.A.2, 1993), 2 F.3d 29, 30 ; Spallone v. United States (1988), 487 U.S. 1251, 1257 , 109 S.Ct. 14 , 101 L.Ed.2d 964 (memorandum decision). | 1 | 2004–2004 |
Vasquez v. California
green
1 sentence2004In re Grand Jury Proceedings (C.A.7, 2002), 280 F.3d 1103, 1110 (“a fine assessed for civil contempt does not implicate the Excessive Fines Clause”), citing United States v. Mongelli (C.A.2, 1993), 2 F.3d 29, 30 ; Spallone v. United States (1988), 487 U.S. 1251, 1257 , 109 S.Ct. 14 , 101 L.Ed.2d 964 (memorandum decision). | 1 | 2004–2004 |
Austin v. United States
green
2 sentences1996Appellant cites Austin v. United States (1993), 509 U.S. 602, 608-610 , 113 S.Ct. 2801, 2805 , 125 L.Ed.2d 488, 496-498 , for the propositions that “the excessive fines clause limits the government’s power to extract payment * * * as punishment” and that the Excessive Fines Clause applies to both civil and criminal law. 1996Appellant cites Austin v. United States (1993), 509 U.S. 602, 608-610 , 113 S.Ct. 2801, 2805 , 125 L.Ed.2d 488, 496-498 , for the propositions that “the excessive fines clause limits the government’s power to extract payment * * * as punishment” and that the Excessive Fines Clause applies to both civil and criminal law. | 1 | 1996–1996 |
United States v. Ferris Alexander
green
1 sentence1995Wild, supra, 47 F.3d at 674 ; Alexander II, supra, 32 F.3d at 1237 . | 1 | 1995–1995 |
United States v. Kenneth A. Wild, (Two Cases). United States of America v. Tyrone E. Greenfield
green
1 sentence1995Wild, supra, 47 F.3d at 674 ; Alexander II, supra, 32 F.3d at 1237 . | 1 | 1995–1995 |
United States v. Certain Real Property
green
1 sentence1995See Shelly’s Riverside Hts., supra, 851 F.Supp. at 638 ; 11869 Westshore Dr., supra, 848 F.Supp. at 111 ; United States ex rel. | 1 | 1995–1995 |
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.