Wilcox rule (Ohio) · Go Syfert
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Wilcox rule in Ohio

10 Ohio opinions name it 2 courts 1989–2025 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 (7)

CaseFollowedCited
State v. Cooeygreen
ohio · 1989 · cited in 5 Ohio opinions naming this issue, 1994–2015
2 sentences

2015See also State v. Cooey, 46 Ohio St.3d 20, 26 , 544 N.E2d 895 (1989) (“The Wilcox rule is based on a mistrust of the ability of psychiatry to accurately ‘fine-tune’ degrees of capacity among offenders who are sane - i.e., who have the minimal capacity to act voluntarily.”). {¶35} This prohibition typically relates to psychiatric testimony proffered to disprove a mental state (unrelated to the affirmative defense of insanity).

2015See also State v. Cooey, 46 Ohio St.3d 20, 26 , 544 N.E2d 895 (1989) (“The Wilcox rule is based on a mistrust of the ability of psychiatry to accurately ‘fine-tune’ degrees of capacity among offenders who are sane - i.e., who have the minimal capacity to act voluntarily.”). {¶35} This prohibition typically relates to psychiatric testimony proffered to disprove a mental state (unrelated to the affirmative defense of insanity).

45
State v. Wilcoxgreen
ohio · 1982 · cited in 3 Ohio opinions naming this issue, 1989–2015
2 sentences

1994Fourth Assignment of Error “The trial court erred to the prejudice of the defendant by refusing to allow expert testimony that the defendant’s underlying psychological condition in combination with several other stressors diminished her capacity to form the requisite mental state necessary for conviction of the crime of felonious assault, State v. Wilcox (1982), 70 Ohio St.2d 182 [ 24 O.O.3d 284 , 436 N.E.2d 523 ], to the contrary notwithstanding.” Defendant also asserts in her supplemental brief the following related assignment of error: “The Wilcox rule is unconstitutional as applied or, at

1994Fourth Assignment of Error “The trial court erred to the prejudice of the defendant by refusing to allow expert testimony that the defendant’s underlying psychological condition in combination with several other stressors diminished her capacity to form the requisite mental state necessary for conviction of the crime of felonious assault, State v. Wilcox (1982), 70 Ohio St.2d 182 [ 24 O.O.3d 284 , 436 N.E.2d 523 ], to the contrary notwithstanding.” Defendant also asserts in her supplemental brief the following related assignment of error: “The Wilcox rule is unconstitutional as applied or, at

13
State v. MacDonaldgreen
ohio · 1976 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Section 10, Article I of the Ohio Constitution guarantees an accused this same right.” State v. Hughes, 86 Ohio St.3d 424 , 425 1999-Ohio-118 , citing State v. MacDonald, 48 Ohio St.2d 66, 68 (1976).

11
State v. Brummett, Unpublished Decision (1-28-2004)green
ohioctapp · 2004 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025As of the date Wilcox filed his motion to dismiss, the record does not reflect he had complied with either the trial court’s June 16, 2023 order or the State’s motion for reciprocal discover. {¶14} “Under 2945.72(D), the speedy trial period can be tolled for ‘[a]ny period of delay occasioned by the neglect or improper act of the accused.’” State v. Bradley, 2005- Ohio-6572, ¶ 27 (11th Dist.) “Courts in Ohio have repeatedly held that when the State lawfully requests reciprocal discovery from the defendant and the defendant fails to comply, the speedy trial time remains tolled and is charged to

11
State v. Saxon, Unpublished Decision (9-23-2004)green
ohioctapp · 2004 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025As of the date Wilcox filed his motion to dismiss, the record does not reflect he had complied with either the trial court’s June 16, 2023 order or the State’s motion for reciprocal discover. {¶14} “Under 2945.72(D), the speedy trial period can be tolled for ‘[a]ny period of delay occasioned by the neglect or improper act of the accused.’” State v. Bradley, 2005- Ohio-6572, ¶ 27 (11th Dist.) “Courts in Ohio have repeatedly held that when the State lawfully requests reciprocal discovery from the defendant and the defendant fails to comply, the speedy trial time remains tolled and is charged to

11
Hagood v. Gailgreen
ohioctapp · 1995 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See Hagood v. Gail, 105 Ohio App.3d 780, 790-791 , 664 N.E.2d 1373 (11th Dist.1995); and Spencer 7 Case No. 2023-P-0059 v. Kiowa Developing Co., 9th Dist.

2024See Hagood v. Gail, 105 Ohio App.3d 780, 790-791 , 664 N.E.2d 1373 (11th Dist.1995); and Spencer 7 Case No. 2023-P-0059 v. Kiowa Developing Co., 9th Dist.

11
United States v. Scheffergreen
scotus · 1998 · cited in 1 Ohio opinions naming this issue, 2011–2011
2 sentences

2011(Citing United States v. Scheffer, 523 U.S. 303 , ---- - ----, 118 S.Ct. 1261, 1263-64, 140 ).

2011(Citing United States v. Scheffer, 523 U.S. 303 , ---- - ----, 118 S.Ct. 1261, 1263-64, 140 ).

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 (11)

CaseCitedYears
State v. Hughes green
ohio · 1999
1 sentence

2025Section 10, Article I of the Ohio Constitution guarantees an accused this same right.” State v. Hughes, 86 Ohio St.3d 424 , 425 1999-Ohio-118 , citing State v. MacDonald, 48 Ohio St.2d 66, 68 (1976).

12025–2025
State v. Hughes green
ohio · 1999
1 sentence

2025Section 10, Article I of the Ohio Constitution guarantees an accused this same right.” State v. Hughes, 86 Ohio St.3d 424 , 425 1999-Ohio-118 , citing State v. MacDonald, 48 Ohio St.2d 66, 68 (1976).

12025–2025
State v. Moine green
ohioctapp · 1991
2 sentences

2013In State v. Moine, 72 Ohio App.3d 584 (9th Dist.1991), we held that the defendant was not entitled to raise the issue of involuntariness/unconsciousness because R.C. 4511.19(A)(1) is a strict liability offense.

2013In State v. Moine, 72 Ohio App.3d 584 (9th Dist.1991), we held that the defendant was not entitled to raise the issue of involuntariness/unconsciousness because R.C. 4511.19(A)(1) is a strict liability offense.

12013–2013
Carrie C. Wong v. Christine Money, Warden Attorney General of the State of Ohio green
ca6 · 1998
2 sentences

2011(T. at 19). {¶58} The application of the Wilcox rule in the case at bar has not “significantly undermined fundamental elements of the accused's defense.” United States v. Wong (6th Cir 1998), 142 F.3d 313, 325 .

2011(T. at 19). {¶58} The application of the Wilcox rule in the case at bar has not “significantly undermined fundamental elements of the accused's defense.” United States v. Wong (6th Cir 1998), 142 F.3d 313, 325 .

12011–2011
State v. Wong green
ohioctapp · 1994
1 sentence

2003We therefore hold that a defendant may not offer expert psychiatric testimony unrelated to the insanity defense * * * to show that, due to mental illness, intoxication, or any other reason, he lacked the mental capacity to form the specific mental state required for a particular crime or degree of crime." Cooey , at 26. {¶ 72} Moreover, in State v. Wong (1994), 95 Ohio App.3d 39 , the Fourth Appellate District performed a thorough survey of whether exclusion of psychiatric testimony on the issue of mens rea or specific intent violates a defendant's constitutional rights.

12003–2003
State v. Rhodes green
ohio · 1992
2 sentences

1994While it is true that reasonable provocation is an affirmative defense which the defendant has the burden of establishing at trial, see State v. Rhodes (1992), 63 Ohio St.3d 613 , 590 N.E.2d 261 , appellant’s argument must still be rejected.

1994While it is true that reasonable provocation is an affirmative defense which the defendant has the burden of establishing at trial, see State v. Rhodes (1992), 63 Ohio St.3d 613 , 590 N.E.2d 261 , appellant’s argument must still be rejected.

11994–1994
State v. Freeman neutral
ohioctyctashtab · 1985
2 sentences

1990In State v. Wilcox (1974), 40 Ohio App. 2d 380 , at paragraph two of the syllabus, the court held: "A person may not be convicted of speeding solely upon evidence obtained from a radar speed-meter device mounted in a moving patrol car in the absence of (1) expert testimony with respect to construction of the device and its method of operation with respect to its ability to differentiate the speed of a vehicle approaching the moving patrol car from the opposite direction from the combined speed at which the two vehicles are moving toward each other, and (2) evidence that the device is in good c

1990In State v. Wilcox (1974), 40 Ohio App. 2d 380 , at paragraph two of the syllabus, the court held: "A person may not be convicted of speeding solely upon evidence obtained from a radar speed-meter device mounted in a moving patrol car in the absence of (1) expert testimony with respect to construction of the device and its method of operation with respect to its ability to differentiate the speed of a vehicle approaching the moving patrol car from the opposite direction from the combined speed at which the two vehicles are moving toward each other, and (2) evidence that the device is in good c

11990–1990
State v. Colby green
ohioctapp · 1984
2 sentences

1990In State v. Wilcox (1974), 40 Ohio App. 2d 380 , at paragraph two of the syllabus, the court held: "A person may not be convicted of speeding solely upon evidence obtained from a radar speed-meter device mounted in a moving patrol car in the absence of (1) expert testimony with respect to construction of the device and its method of operation with respect to its ability to differentiate the speed of a vehicle approaching the moving patrol car from the opposite direction from the combined speed at which the two vehicles are moving toward each other, and (2) evidence that the device is in good c

1990In State v. Wilcox (1974), 40 Ohio App. 2d 380 , at paragraph two of the syllabus, the court held: "A person may not be convicted of speeding solely upon evidence obtained from a radar speed-meter device mounted in a moving patrol car in the absence of (1) expert testimony with respect to construction of the device and its method of operation with respect to its ability to differentiate the speed of a vehicle approaching the moving patrol car from the opposite direction from the combined speed at which the two vehicles are moving toward each other, and (2) evidence that the device is in good c

11990–1990
State v. Doles green
ohioctapp · 1980
2 sentences

1990In accord Kirtland Hills v. Logan (1984), 21 Ohio App. 3d 67 ; State v. Doles (1980), 70 Ohio App. 2d 35 .

1990In accord Kirtland Hills v. Logan (1984), 21 Ohio App. 3d 67 ; State v. Doles (1980), 70 Ohio App. 2d 35 .

11990–1990
Village of Kirtland Hills v. Logan neutral
ohioctapp · 1984
2 sentences

1990In accord Kirtland Hills v. Logan (1984), 21 Ohio App. 3d 67 ; State v. Doles (1980), 70 Ohio App. 2d 35 .

1990In accord Kirtland Hills v. Logan (1984), 21 Ohio App. 3d 67 ; State v. Doles (1980), 70 Ohio App. 2d 35 .

11990–1990
State v. Wilcox green
ohioctapp · 1974
2 sentences

1990In State v. Wilcox (1974), 40 Ohio App. 2d 380 , at paragraph two of the syllabus, the court held: "A person may not be convicted of speeding solely upon evidence obtained from a radar speed-meter device mounted in a moving patrol car in the absence of (1) expert testimony with respect to construction of the device and its method of operation with respect to its ability to differentiate the speed of a vehicle approaching the moving patrol car from the opposite direction from the combined speed at which the two vehicles are moving toward each other, and (2) evidence that the device is in good c

1990In State v. Wilcox (1974), 40 Ohio App. 2d 380 , at paragraph two of the syllabus, the court held: "A person may not be convicted of speeding solely upon evidence obtained from a radar speed-meter device mounted in a moving patrol car in the absence of (1) expert testimony with respect to construction of the device and its method of operation with respect to its ability to differentiate the speed of a vehicle approaching the moving patrol car from the opposite direction from the combined speed at which the two vehicles are moving toward each other, and (2) evidence that the device is in good c

11990–1990

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2901.01 (4) OH § Ohio Rev. Code § 2901.22 (4) OH § Ohio Rev. Code § 2901.05 (3) OH § Ohio Rev. Code § 2903.11 (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 10 (1989–2025) IL 6 (1976–2019) FL 5 (1985–2014) CA 4 (1979–2015) NY 2 (1908–2010) VT 2 (2007–2015)

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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