speculative inquiry (Ohio) · Go Syfert
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speculative inquiry in Ohio

10 Ohio opinions name it 2 courts 1993–2023 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 (4)

CaseFollowedCited
United States v. Gonzalez-Lopezgreen
scotus · 2006 · cited in 2 Ohio opinions naming this issue, 2011–2022
2 sentences

2022See Gonzalez-Lopez, 548 U.S. at 150 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (“Harmless- error analysis in such a context would be a speculative inquiry into what might have occurred in an alternate universe”). {¶ 31} The errors that occurred in Montgomery’s trial are not akin to the state’s vouching for the credibility of a witness, see State v. Myers, 154 Ohio St.3d 405 , 2018-Ohio-1903 , 114 N.E.3d 1138, ¶ 145 (explaining that vouching occurs when the prosecutor implies knowledge of facts outside the record or expresses a personal opinion about the credibility of a witness).

2022See Gonzalez-Lopez, 548 U.S. at 150 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (“Harmless- error analysis in such a context would be a speculative inquiry into what might have occurred in an alternate universe”). {¶ 31} The errors that occurred in Montgomery’s trial are not akin to the state’s vouching for the credibility of a witness, see State v. Myers, 154 Ohio St.3d 405 , 2018-Ohio-1903 , 114 N.E.3d 1138, ¶ 145 (explaining that vouching occurs when the prosecutor implies knowledge of facts outside the record or expresses a personal opinion about the credibility of a witness).

12
In re Tanksleygreen
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023Franklin No. 15AP-1085, 2016-Ohio-7068, ¶ 12-13 (petitioner seeking a CQE to receive certified public accountant licensure “fails at the threshold” where requirement for granting certified public account licensure is that “the person is of good moral character;” “[w]hile petitioner’s felony convictions certainly would count against him in the overall assessment of good moral character, the convictions do not specifically prevent him from receiving approval, and like all other applicants, he must satisfy the Board that he has ‘good moral character.’”). {¶ 26} If the trial court finds that Deran

11
State v. Myers (Slip Opinion)green
ohio · 2018 · cited in 1 Ohio opinions naming this issue, 2022–2022
2 sentences

2022See Gonzalez-Lopez, 548 U.S. at 150 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (“Harmless- error analysis in such a context would be a speculative inquiry into what might have occurred in an alternate universe”). {¶ 31} The errors that occurred in Montgomery’s trial are not akin to the state’s vouching for the credibility of a witness, see State v. Myers, 154 Ohio St.3d 405 , 2018-Ohio-1903 , 114 N.E.3d 1138, ¶ 145 (explaining that vouching occurs when the prosecutor implies knowledge of facts outside the record or expresses a personal opinion about the credibility of a witness).

2022See Gonzalez-Lopez, 548 U.S. at 150 , 126 S.Ct. 2557 , 165 L.Ed.2d 409 (“Harmless- error analysis in such a context would be a speculative inquiry into what might have occurred in an alternate universe”). {¶ 31} The errors that occurred in Montgomery’s trial are not akin to the state’s vouching for the credibility of a witness, see State v. Myers, 154 Ohio St.3d 405 , 2018-Ohio-1903 , 114 N.E.3d 1138, ¶ 145 (explaining that vouching occurs when the prosecutor implies knowledge of facts outside the record or expresses a personal opinion about the credibility of a witness).

11
Tanner v. United Statesgreen
scotus · 1987 · cited in 1 Ohio opinions naming this issue, 2003–2003
2 sentences

2003See Tanner v. United States (1987), 483 U.S. 107, 117 , 107 S.Ct. 2739 , 97 L.Ed.2d 90 . {¶ 45} Our role in reviewing for plain error does not allow us to indulge in an in-depth analysis of a jury’s deliberations.

2003See Tanner v. United States (1987), 483 U.S. 107, 117 , 107 S.Ct. 2739 , 97 L.Ed.2d 90 . {¶ 45} Our role in reviewing for plain error does not allow us to indulge in an in-depth analysis of a jury’s deliberations.

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 (9)

CaseCitedYears
State v. Lang green
ohio · 2011
2 sentences

2022Although Brown’s initial statement to police was not consistent with her trial testimony, there is no evidence that her trial testimony was inconsistent with her grand jury testimony. “[T]he mere possibility of inconsistent testimony does not rise to the level of a particularized need that would warrant the disclosure of grand-jury testimony.” State v. Ford, 158 Ohio St.3d 139 , 2019-Ohio-4539 , 140 N.E.3d 616 , ¶ 396, citing State v Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 44 (holding that a speculative claim that the grand jury testimony might have contained material ev

2022Although Brown’s initial statement to police was not consistent with her trial testimony, there is no evidence that her trial testimony was inconsistent with her grand jury testimony. “[T]he mere possibility of inconsistent testimony does not rise to the level of a particularized need that would warrant the disclosure of grand-jury testimony.” State v. Ford, 158 Ohio St.3d 139 , 2019-Ohio-4539 , 140 N.E.3d 616 , ¶ 396, citing State v Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 44 (holding that a speculative claim that the grand jury testimony might have contained material ev

22012–2022
State v. Frost green
ohioctapp · 1984
2 sentences

1993In re Sublett (1959), 169 Ohio St. 19 , 7 O.O.2d 487 , 157 N.E.2d 324 ; State v. Frost, supra, 14 Ohio App.3d at 321 , 14 OBR at 387, 471 N.E.2d at 173 .

1993In re Sublett (1959), 169 Ohio St. 19 , 7 O.O.2d 487 , 157 N.E.2d 324 ; State v. Frost, supra, 14 Ohio App.3d at 321 , 14 OBR at 387, 471 N.E.2d at 173 .

21993–1993
City of Cincinnati v. Vester. Same v. Richards Same v. Reakirt green
scotus · 1930
2 sentences

2022Sun Oil Co. v. Euclid, 164 Ohio St. 265 , 271-272, 130 N.E.2d 336 (1955), citing Cincinnati v. Vester, 281 U.S. 439 , 448, 50 S.Ct. 360 , 74 L.Ed. 950 (1930). 20 January Term, 2022 {¶ 54} Here, the trial court determined that “the word ‘necessary,’ as used in acts conferring the right of eminent domain, does not mean ‘absolutely necessary’ or ‘indispensable,’ but, rather, ‘reasonably necessary to secure the end in view.’ ” Licking C.P.

2022Sun Oil Co. v. Euclid, 164 Ohio St. 265 , 271-272, 130 N.E.2d 336 (1955), citing Cincinnati v. Vester, 281 U.S. 439 , 448, 50 S.Ct. 360 , 74 L.Ed. 950 (1930). 20 January Term, 2022 {¶ 54} Here, the trial court determined that “the word ‘necessary,’ as used in acts conferring the right of eminent domain, does not mean ‘absolutely necessary’ or ‘indispensable,’ but, rather, ‘reasonably necessary to secure the end in view.’ ” Licking C.P.

12022–2022
Gideon v. Wainwright green
scotus · 1963
2 sentences

2022Instead, like other structural errors that infect the entire framework of the trial from beginning to end, see Tumey (denial of right to impartial judge), and Gideon v. Wainwright, 372 U.S. 335 , 83 S.Ct. 792 , 9 L.Ed.2d 799 (1963) (denial of right to counsel), the errors in this case influenced the entire trial; the errors conflated the role of the victim and prosecutor and transcended the criminal process.

2022Instead, like other structural errors that infect the entire framework of the trial from beginning to end, see Tumey (denial of right to impartial judge), and Gideon v. Wainwright, 372 U.S. 335 , 83 S.Ct. 792 , 9 L.Ed.2d 799 (1963) (denial of right to counsel), the errors in this case influenced the entire trial; the errors conflated the role of the victim and prosecutor and transcended the criminal process.

12022–2022
City of Norwood v. Horney green
ohio · 2006
2 sentences

2022Such a speculative standard is inappropriate in the context of eminent domain, even under the modern, broad interpretation of ‘public use.’ ” Norwood, 110 Ohio St.3d 353 , 2006-Ohio-3799 , 853 N.E.2d 1115 , at ¶ 99. {¶ 53} This court explained, “A municipality has no authority to appropriate private property for only a contemplated or speculative use in the future.” Id. at ¶ 100, citing State ex rel.

2022Such a speculative standard is inappropriate in the context of eminent domain, even under the modern, broad interpretation of ‘public use.’ ” Norwood, 110 Ohio St.3d 353 , 2006-Ohio-3799 , 853 N.E.2d 1115 , at ¶ 99. {¶ 53} This court explained, “A municipality has no authority to appropriate private property for only a contemplated or speculative use in the future.” Id. at ¶ 100, citing State ex rel.

12022–2022
State v. Ford (Slip Opinion) green
ohio · 2019
1 sentence

2022Although Brown’s initial statement to police was not consistent with her trial testimony, there is no evidence that her trial testimony was inconsistent with her grand jury testimony. “[T]he mere possibility of inconsistent testimony does not rise to the level of a particularized need that would warrant the disclosure of grand-jury testimony.” State v. Ford, 158 Ohio St.3d 139 , 2019-Ohio-4539 , 140 N.E.3d 616 , ¶ 396, citing State v Lang, 129 Ohio St.3d 512 , 2011-Ohio-4215 , 954 N.E.2d 596 , ¶ 44 (holding that a speculative claim that the grand jury testimony might have contained material ev

12022–2022
Cincinnati v. Vester green
scotus · 1930
2 sentences

2022Sun Oil Co. v. Euclid, 164 Ohio St. 265 , 271-272, 130 N.E.2d 336 (1955), citing Cincinnati v. Vester, 281 U.S. 439 , 448, 50 S.Ct. 360 , 74 L.Ed. 950 (1930). 20 January Term, 2022 {¶ 54} Here, the trial court determined that “the word ‘necessary,’ as used in acts conferring the right of eminent domain, does not mean ‘absolutely necessary’ or ‘indispensable,’ but, rather, ‘reasonably necessary to secure the end in view.’ ” Licking C.P.

2022Sun Oil Co. v. Euclid, 164 Ohio St. 265 , 271-272, 130 N.E.2d 336 (1955), citing Cincinnati v. Vester, 281 U.S. 439, 448 , 50 S.Ct. 360 , 74 L.Ed. 950 (1930). 20 January Term, 2022 {¶ 54} Here, the trial court determined that “the word ‘necessary,’ as used in acts conferring the right of eminent domain, does not mean ‘absolutely necessary’ or ‘indispensable,’ but, rather, ‘reasonably necessary to secure the end in view.’ ” Licking C.P.

12022–2022
State v. Steffen green
ohio · 1987
2 sentences

2004The proportionality review mandated by R.C. 2929.05 is reserved for appellate courts and “is satisfied by ‘a review of those cases already decided by the reviewing court in which the death penalty has been imposed.’ ” State v. Sneed (1992), 63 Ohio St.3d 3, 17 , 584 N.E.2d 1160 , quoting Steffen, 31 Ohio St.3d 111 , 31 OBR 273, 509 N.E.2d 383 , paragraph one of the syllabus.

2004The proportionality review mandated by R.C. 2929.05 is reserved for appellate courts and “is satisfied by ‘a review of those cases already decided by the reviewing court in which the death penalty has been imposed.’ ” State v. Sneed (1992), 63 Ohio St.3d 3, 17 , 584 N.E.2d 1160 , quoting Steffen, 31 Ohio St.3d 111 , 31 OBR 273, 509 N.E.2d 383 , paragraph one of the syllabus.

12004–2004
State v. Sneed green
ohio · 1992
2 sentences

2004The proportionality review mandated by R.C. 2929.05 is reserved for appellate courts and “is satisfied by ‘a review of those cases already decided by the reviewing court in which the death penalty has been imposed.’ ” State v. Sneed (1992), 63 Ohio St.3d 3, 17 , 584 N.E.2d 1160 , quoting Steffen, 31 Ohio St.3d 111 , 31 OBR 273, 509 N.E.2d 383 , paragraph one of the syllabus.

2004The proportionality review mandated by R.C. 2929.05 is reserved for appellate courts and “is satisfied by ‘a review of those cases already decided by the reviewing court in which the death penalty has been imposed.’ ” State v. Sneed (1992), 63 Ohio St.3d 3, 17 , 584 N.E.2d 1160 , quoting Steffen, 31 Ohio St.3d 111 , 31 OBR 273, 509 N.E.2d 383 , paragraph one of the syllabus.

12004–2004

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.01 (3) OH § Ohio Rev. Code § 2929.04 (3) OH § Ohio Rev. Code § 2929.05 (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

CA 34 (1984–2025) NY 15 (1955–2026) PA 13 (1915–2025) TX 12 (1984–2025) OH 10 (1993–2023) WA 9 (1911–2018) CO 9 (1944–2026) MS 7 (1988–2022) MA 7 (2005–2025) IA 5 (2011–2025) VA 4 (1998–2026) AL 4 (1956–2026) CT 4 (1987–2015) FL 4 (1986–2025) KS 4 (1909–2026) IL 3 (2022–2025) AZ 3 (2004–2017) KY 2 (2010–2019) NM 2 (2014–2014) MO 2 (2014–2014) GA 2 (2015–2021) MI 2 (1994–2015) NV 2 (1995–2011) LA 2 (1978–2012) OK 2 (2017–2017)

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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