70 Ohio opinions name it 2 courts 2016–2026 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. Lundygreen2 sentences2020Cuyahoga No. 105117, 2017-Ohio-9155, ¶ 26 (“Although Logan predates Ruff, Ohio courts continue to apply the guidelines set forth in Logan to determine whether * * * offenses were committed with a separate animus, in accordance with the third prong of the Ruff test.”). -9- Case No. 1-19-27, 1-19-28 {¶16} “‘“Like all mental states, animus is often difficult to prove directly, but must be inferred from the surrounding circumstances.”’” Frye, 2018-Ohio-894, at ¶ 132 , quoting Ramey at ¶ 71, quoting Logan at 131 . “‘“Thus the manner in which a defendant engages in a course of conduct may indicate d 2020Cuyahoga No. 105117, 2017-Ohio-9155, ¶ 26 (“Although Logan predates Ruff, Ohio courts continue to apply the guidelines set forth in Logan to determine whether * * * offenses were committed with a separate animus, in accordance with the third prong of the Ruff test.”). -9- Case No. 1-19-27, 1-19-28 {¶16} “‘“Like all mental states, animus is often difficult to prove directly, but must be inferred from the surrounding circumstances.”’” Frye, 2018-Ohio-894, at ¶ 132 , quoting Ramey at ¶ 71, quoting Logan at 131 . “‘“Thus the manner in which a defendant engages in a course of conduct may indicate d | 3 | 5 |
State v. Washingtongreen2 sentences2018State v. Washington , 137 Ohio St.3d 427 , 2013-Ohio-4982 , 999 N.E.2d 661 , ¶ 18, citing State v. Mughni , 33 Ohio St.3d 65 , 67, 514 N.E.2d 870 (1987). {¶ 18} Under the Ruff test, we first address whether the aggravated burglary and rape offenses were "dissimilar in import"-i.e., whether the offenses involved separate victims or "separate and identifiable" harm. {¶ 19} Whether the aggravated burglary and rape offenses involved separate victims is not a simple issue given that three of C.G.'s children, her 9-year-old daughter and 1-year-old twin boys, were asleep in their beds when Roberson t 2018State v. Washington , 137 Ohio St.3d 427 , 2013-Ohio-4982 , 999 N.E.2d 661 , ¶ 18, citing State v. Mughni , 33 Ohio St.3d 65 , 67, 514 N.E.2d 870 (1987). {¶ 18} Under the Ruff test, we first address whether the aggravated burglary and rape offenses were "dissimilar in import"-i.e., whether the offenses involved separate victims or "separate and identifiable" harm. {¶ 19} Whether the aggravated burglary and rape offenses involved separate victims is not a simple issue given that three of C.G.'s children, her 9-year-old daughter and 1-year-old twin boys, were asleep in their beds when Roberson t | 1 | 2 |
State v. Jackson (Slip Opinion)green2 sentences2022State v. Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , 34 N.E.3d 892, ¶ 31 ; State v. Jackson, 149 Ohio St.3d 55 , 2016-Ohio-5488 , 73 N.E.3d 414, ¶ 128-129 (applying Ruff test to merger of aggravating circumstances). 2022State v. Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , 34 N.E.3d 892, ¶ 31 ; State v. Jackson, 149 Ohio St.3d 55 , 2016-Ohio-5488 , 73 N.E.3d 414, ¶ 128-129 (applying Ruff test to merger of aggravating circumstances). | 1 | 2 |
State v. Armengaugreen2 sentences2018"Although Logan predates Ruff , Ohio courts continue to apply the guidelines set forth in Logan in determining whether kidnapping and another offense were committed with a separate animus, in accordance with the third prong of the Ruff test." State v. Asadi-Ousley , 2017-Ohio-7252 , 102 N.E.3d 52 , ¶ 47, reopened on other grounds , citing State v. Armengau , 2017-Ohio-4452 , 93 N.E.3d 284 , ¶ 125, State v. Williams , 2015-Ohio-4100 , 43 N.E.3d 797 , ¶ 18, and State v. Stinnett , 5th Dist. 2018"Although Logan predates Ruff , Ohio courts continue to apply the guidelines set forth in Logan in determining whether kidnapping and another offense were committed with a separate animus, in accordance with the third prong of the Ruff test." State v. Asadi-Ousley , 2017-Ohio-7252 , 102 N.E.3d 52 , ¶ 47, reopened on other grounds , citing State v. Armengau , 2017-Ohio-4452 , 93 N.E.3d 284 , ¶ 125, State v. Williams , 2015-Ohio-4100 , 43 N.E.3d 797 , ¶ 18, and State v. Stinnett , 5th Dist. | 1 | 2 |
State v. Smithgreen2 sentences2026State v. Smith, 2023-Ohio-866, ¶ 9 (6th Dist.), citing Ruff at ¶ 30 . 2026State v. Smith, 2023-Ohio-866, ¶ 9 (6th Dist.), citing Ruff at ¶ 30 . | 1 | 1 |
State v. Hymergreen2 sentences2026See State v. Hymer, 2025-Ohio-1691, ¶ 26 (12th Dist.) (finding dissimilar import "[b]ased on the limited record before us"); see also State v. Washington, 2013-Ohio-4982, ¶ 24 (stating that "when deciding whether to merge multiple offenses at sentencing pursuant to R.C. 2941.25, a court must review the entire record"). 2026See State v. Hymer, 2025-Ohio-1691, ¶ 26 (12th Dist.) (finding dissimilar import "[b]ased on the limited record before us"); see also State v. Washington, 2013-Ohio-4982, ¶ 24 (stating that "when deciding whether to merge multiple offenses at sentencing pursuant to R.C. 2941.25, a court must review the entire record"). | 1 | 1 |
State v. Akinsgreen2 sentences2026“Offenses are dissimilar in import or significance within the meaning of R.C. 2941.25(B) ‘when the defendant’s conduct constitutes offenses involving separate victims or if the harm that results from each offense is separate and identifiable.’” Akins at ¶ 39 (8th Dist.), quoting Ruff, 2015-Ohio-995, at ¶ 23. 2026“Offenses are dissimilar in import or significance within the meaning of R.C. 2941.25(B) ‘when the defendant’s conduct constitutes offenses involving separate victims or if the harm that results from each offense is separate and identifiable.’” Akins at ¶ 39 (8th Dist.), quoting Ruff, 2015-Ohio-995, at ¶ 23. | 1 | 1 |
State v. Killingsworthgreen2 sentences2026State v. Killingsworth, 2020-Ohio-724, ¶ 15, fn. 3 (3d Dist.); State v. Lundy, 2017-Ohio-9155, ¶ 26 (8th Dist.). 2026State v. Killingsworth, 2020-Ohio-724, ¶ 15, fn. 3 (3d Dist.); State v. Lundy, 2017-Ohio-9155, ¶ 26 (8th Dist.). | 1 | 1 |
State v. Dean (Slip Opinion)green2 sentences2025Accord State v. Dean, 2015-Ohio-4347, ¶ 204 ; State v. Barron, 2024-Ohio-5836, ¶ 43 (2d Dist.). {¶ 64} We apply a de novo standard of review when evaluating R.C. 2941.25 merger decisions. 2025Accord State v. Dean, 2015-Ohio-4347, ¶ 204 ; State v. Barron, 2024-Ohio-5836, ¶ 43 (2d Dist.). {¶ 64} We apply a de novo standard of review when evaluating R.C. 2941.25 merger decisions. | 1 | 1 |
State v. Barrongreen2 sentences2025Accord State v. Dean, 2015-Ohio-4347, ¶ 204 ; State v. Barron, 2024-Ohio-5836, ¶ 43 (2d Dist.). {¶ 64} We apply a de novo standard of review when evaluating R.C. 2941.25 merger decisions. 2025Accord State v. Dean, 2015-Ohio-4347, ¶ 204 ; State v. Barron, 2024-Ohio-5836, ¶ 43 (2d Dist.). {¶ 64} We apply a de novo standard of review when evaluating R.C. 2941.25 merger decisions. | 1 | 1 |
State v. Taylor-Hollingsworthgreen2 sentences2024See Taylor-Hollingsworth, 2023-Ohio-4435, at ¶ 28 (holding that if any of the Ruff factors is met, the offenses do not merge). 2024See Taylor-Hollingsworth, 2023-Ohio-4435, at ¶ 28 (holding that if any of the Ruff factors is met, the offenses do not merge). | 1 | 1 |
State v. Saxtongreen2 sentences2024Franklin No. 18AP-925, 2019-Ohio-5257, ¶ 41 (arguing that the appellate court “need not engage in the Ruff analysis because R.C. 2925.11, the possession statute, indicates -26- Case Nos. 1-23-17, 1-23-18 and 1-23-19 a legislative intent to calibrate the punishment for the offense based on the aggregate drug weight”). {¶51} Typically, “‘where two statutory provisions proscribe the “same offense,” they are construed not to authorize cumulative punishments in the absence of a clear indication of contrary legislative intent.’” (Emphasis sic.) Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , at ¶ 11, quo 2024Franklin No. 18AP-925, 2019-Ohio-5257, ¶ 41 (arguing that the appellate court “need not engage in the Ruff analysis because R.C. 2925.11, the possession statute, indicates -26- Case Nos. 1-23-17, 1-23-18 and 1-23-19 a legislative intent to calibrate the punishment for the offense based on the aggregate drug weight”). {¶51} Typically, “‘where two statutory provisions proscribe the “same offense,” they are construed not to authorize cumulative punishments in the absence of a clear indication of contrary legislative intent.’” (Emphasis sic.) Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , at ¶ 11, quo | 1 | 1 |
State v. McKnightgreen1 sentence2023McKnight, 2022-Ohio-591, at ¶ 35 (“We note again that Ruff directed that if any one of the three prongs is met, the counts do not merge.”). {¶ 29} Appellant’s sole assignment of error is overruled. | 1 | 1 |
State v. Ramunasgreen2 sentences2023Rather, an allied-offenses analysis must be driven by the facts of each case.” State v. Ramunas, __Ohio St.3d__, 2022-Ohio-4199, ¶ 22 (Fischer, J., dissenting). “[B]ecause an offense may be committed in a variety of ways[,] and the offenses committed may have different import,” the Ruff analysis must focus on the appellant’s conduct to resolve whether one or more convictions may result. 2023Rather, an allied-offenses analysis must be driven by the facts of each case.” State v. Ramunas, __Ohio St.3d__, 2022-Ohio-4199, ¶ 22 (Fischer, J., dissenting). “[B]ecause an offense may be committed in a variety of ways[,] and the offenses committed may have different import,” the Ruff analysis must focus on the appellant’s conduct to resolve whether one or more convictions may result. | 1 | 1 |
| State v. Crossleygreen | 1 | 1 |
| State v. Grate (Slip Opinion)green | 1 | 1 |
| State v. Lovatogreen | 1 | 1 |
| State v. Mpanurwagreen | 1 | 1 |
| State v. Robersongreen | 1 | 1 |
| State v. Napiergreen | 1 | 1 |
| State v. Ervin-Williamsgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. LeGrant
green
2 sentences2021Miami No. 2013-CA-44, 2014-Ohio-5803, ¶ 15 . *** We reach the same conclusion under the Ruff standard, which the Ohio Supreme Court applied in Earley. 2021Miami No. 2013-CA-44, 2014-Ohio-5803, ¶ 15 . *** We reach the same conclusion under the Ruff standard, which the Ohio Supreme Court applied in Earley. | 11 | 2016–2021 |
State v. Earley (Slip Opinion)
green
2 sentences2024See R.C. 2941.25; State v. Earley, 2015-Ohio-4615 , ¶ 18 (“[t]he allied-offense statute, R.C. 2941.25, concerns the merger of convictions,” and, “[b]y applying R.C. 2941.25, courts determine whether a defendant can be convicted of multiple offenses” [emphasis in original]). {¶29} Finally, although Cass baldly asserts that “[o]ther combinations of Cass’ eight counts of convictions [sic] could satisfy the Ruff test,” he fails to elaborate any further. 2024See R.C. 2941.25; State v. Earley, 2015-Ohio-4615 , ¶ 18 (“[t]he allied-offense statute, R.C. 2941.25, concerns the merger of convictions,” and, “[b]y applying R.C. 2941.25, courts determine whether a defendant can be convicted of multiple offenses” [emphasis in original]). {¶29} Finally, although Cass baldly asserts that “[o]ther combinations of Cass’ eight counts of convictions [sic] could satisfy the Ruff test,” he fails to elaborate any further. | 9 | 2018–2025 |
State v. Ruff
green
2 sentences2024Franklin No. 18AP-925, 2019-Ohio-5257, ¶ 41 (arguing that the appellate court “need not engage in the Ruff analysis because R.C. 2925.11, the possession statute, indicates -26- Case Nos. 1-23-17, 1-23-18 and 1-23-19 a legislative intent to calibrate the punishment for the offense based on the aggregate drug weight”). {¶51} Typically, “‘where two statutory provisions proscribe the “same offense,” they are construed not to authorize cumulative punishments in the absence of a clear indication of contrary legislative intent.’” (Emphasis sic.) Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , at ¶ 11, quo 2024Franklin No. 18AP-925, 2019-Ohio-5257, ¶ 41 (arguing that the appellate court “need not engage in the Ruff analysis because R.C. 2925.11, the possession statute, indicates -26- Case Nos. 1-23-17, 1-23-18 and 1-23-19 a legislative intent to calibrate the punishment for the offense based on the aggregate drug weight”). {¶51} Typically, “‘where two statutory provisions proscribe the “same offense,” they are construed not to authorize cumulative punishments in the absence of a clear indication of contrary legislative intent.’” (Emphasis sic.) Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , at ¶ 11, quo | 8 | 2016–2024 |
State v. Logan
green
2 sentences2021Id. at syllabus. {¶19} “‘Although Logan predates Ruff, Ohio courts continue to apply the guidelines set forth in Logan in determining whether kidnapping and another offense were committed with a separate animus, in accordance with the third prong of the Ruff test.’” State v. Cook, 11th Dist. 2021Id. at syllabus. {¶19} “‘Although Logan predates Ruff, Ohio courts continue to apply the guidelines set forth in Logan in determining whether kidnapping and another offense were committed with a separate animus, in accordance with the third prong of the Ruff test.’” State v. Cook, 11th Dist. | 7 | 2017–2021 |
State v. Washington
green
2 sentences2023State v. Washington, 137 Ohio St.3d 427 , 2013-Ohio- 4982, 999 N.E.2d 661 , ¶ 18. 11. {¶ 33} Applying the Ruff analysis, we find that appellant’s conduct supports multiple offenses. 2023State v. Washington, 137 Ohio St.3d 427 , 2013-Ohio- 4982, 999 N.E.2d 661 , ¶ 18. 11. {¶ 33} Applying the Ruff analysis, we find that appellant’s conduct supports multiple offenses. | 4 | 2018–2023 |
Collins v. St. Elizabeth Hospital
green
2 sentences2019State v. Washington, 137 Ohio St.3d 427 , 2013-Ohio- 4982, 999 N.E.2d 661 , ¶ 18, citing State v. Mughni, 33 Ohio St.3d 65, 67 , 514 N.E.2d 870 (1987). 10. {¶ 25} Under the Ruff test, we first address whether the sexual battery and extortion offenses were “dissimilar in import”―i.e., whether the offenses involved separate victims or “separate and identifiable” harm. 2019State v. Washington, 137 Ohio St.3d 427 , 2013-Ohio- 4982, 999 N.E.2d 661 , ¶ 18, citing State v. Mughni, 33 Ohio St.3d 65, 67 , 514 N.E.2d 870 (1987). 10. {¶ 25} Under the Ruff test, we first address whether the sexual battery and extortion offenses were “dissimilar in import”―i.e., whether the offenses involved separate victims or “separate and identifiable” harm. | 3 | 2018–2019 |
State v. Dammons
neutral
2 sentences2024E.g., State v. Byers, Cuyahoga App. No. 94922, 2011-Ohio-342 , ¶ 9 (“The ubiquitousness of cell phones is such that the mere possession of a cell phone is not ipso facto proof that it was used in drug trafficking.”)” Id. at ¶ 27, quoting State v. Dammons, 2011-Ohio-2908 (8th Dist.). {¶74} Applying that logic, the court in Olmstead “conclude[d] that the conduct underlying the possession of criminal tools was separate from the conduct underlying the possession of cocaine for the purposes of the Ruff analysis[.]” Id. at ¶ 29. 2018Cuyahoga Nos. 94878, 2011-Ohio-2908, ¶ 24 . {¶ 29} The conduct underlying the possession of criminal tools was, therefore, separate from the conduct underlying the sale and possession of drugs for the purposes of the Ruff analysis and we reject appellant's arguments regarding possession of criminal tools. {¶ 30} Appellant's first assignment of error is overruled. | 2 | 2018–2024 |
State v. Asadi-Ousley
green
2 sentences2018"Although Logan predates Ruff , Ohio courts continue to apply the guidelines set forth in Logan in determining whether kidnapping and another offense were committed with a separate animus, in accordance with the third prong of the Ruff test." State v. Asadi-Ousley , 2017-Ohio-7252 , 102 N.E.3d 52 , ¶ 47, reopened on other grounds , citing State v. Armengau , 2017-Ohio-4452 , 93 N.E.3d 284 , ¶ 125, State v. Williams , 2015-Ohio-4100 , 43 N.E.3d 797 , ¶ 18, and State v. Stinnett , 5th Dist. 2018"Although Logan predates Ruff , Ohio courts continue to apply the guidelines set forth in Logan in determining whether kidnapping and another offense were committed with a separate animus, in accordance with the third prong of the Ruff test." State v. Asadi-Ousley , 2017-Ohio-7252 , 102 N.E.3d 52 , ¶ 47, reopened on other grounds , citing State v. Armengau , 2017-Ohio-4452 , 93 N.E.3d 284 , ¶ 125, State v. Williams , 2015-Ohio-4100 , 43 N.E.3d 797 , ¶ 18, and State v. Stinnett , 5th Dist. | 2 | 2018–2021 |
State v. Cook
green
2 sentences2021Geauga No. 2016-G-0096, 2018-Ohio-788, ¶15 , quoting State v. Asadi-Ousley, 8th Dist. 2021Geauga No. 2016-G-0096, 2018-Ohio-788, ¶15 , quoting State v. Asadi-Ousley, 8th Dist. | 2 | 2019–2021 |
State v. Johnson
green
2 sentences2021Thus, the same set of offenses might yield different results in different cases, “‘given that the statute instructs courts to examine a defendant’s conduct – an inherently subjective determination.’” Id. at ¶ 32, quoting State v. Johnson, 128 Ohio St.3d 153 , 2010-Ohio- 6314, 942 N.E.2d 1061 , ¶ 52 (plurality opinion). {¶ 32} In applying the Ruff analysis, rather than focusing on the various elements of each offense, courts consider three, separate factors: “the conduct, the animus, and the import.” Ruff at paragraph one of the syllabus. 2021Thus, the same set of offenses might yield different results in different cases, “‘given that the statute instructs courts to examine a defendant’s conduct – an inherently subjective determination.’” Id. at ¶ 32, quoting State v. Johnson, 128 Ohio St.3d 153 , 2010-Ohio- 6314, 942 N.E.2d 1061 , ¶ 52 (plurality opinion). {¶ 32} In applying the Ruff analysis, rather than focusing on the various elements of each offense, courts consider three, separate factors: “the conduct, the animus, and the import.” Ruff at paragraph one of the syllabus. | 2 | 2017–2021 |
State v. Sowers
green
2 sentences2020Clark No. 2018-CA-58, 2019-Ohio-649, ¶ 18 , citing State v. Armengau, 10th Dist. 2020Clark No. 2018-CA-58, 2019-Ohio-649, ¶ 18 , citing State v. Armengau, 10th Dist. | 2 | 2019–2020 |
State v. Moore
green
2 sentences2025Id. {¶ 12} Applying the Ruff test to the facts here, we find that Coleman's convictions for aggravated robbery and abduction do not merge. 2025Id. {¶ 12} Applying the Ruff test to the facts here, we find that Coleman's convictions for aggravated robbery and abduction do not merge. | 1 | 2025–2025 |
State v. St. John
green
2 sentences2025John, 2017-Ohio-4043 (11th Dist.), the Eleventh District wrote that under the first prong of the Ruff standard: “[g]ross sexual imposition and rape may, depending on the circumstances, be allied offenses of similar import. 2025John, 2017-Ohio-4043 (11th Dist.), the Eleventh District wrote that under the first prong of the Ruff standard: “[g]ross sexual imposition and rape may, depending on the circumstances, be allied offenses of similar import. | 1 | 2025–2025 |
State v. Damron
green
2 sentences2024State v. Damron, 2011-Ohio-2268, ¶ 17 . {¶38} We now apply a Ruff analysis to appellant’s allied offense argument. 2024State v. Damron, 2011-Ohio-2268, ¶ 17 . {¶38} We now apply a Ruff analysis to appellant’s allied offense argument. | 1 | 2024–2024 |
Whalen v. United States
green
2 sentences2024Franklin No. 18AP-925, 2019-Ohio-5257, ¶ 41 (arguing that the appellate court “need not engage in the Ruff analysis because R.C. 2925.11, the possession statute, indicates -26- Case Nos. 1-23-17, 1-23-18 and 1-23-19 a legislative intent to calibrate the punishment for the offense based on the aggregate drug weight”). {¶51} Typically, “‘where two statutory provisions proscribe the “same offense,” they are construed not to authorize cumulative punishments in the absence of a clear indication of contrary legislative intent.’” (Emphasis sic.) Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , at ¶ 11, quo 2024Franklin No. 18AP-925, 2019-Ohio-5257, ¶ 41 (arguing that the appellate court “need not engage in the Ruff analysis because R.C. 2925.11, the possession statute, indicates -26- Case Nos. 1-23-17, 1-23-18 and 1-23-19 a legislative intent to calibrate the punishment for the offense based on the aggregate drug weight”). {¶51} Typically, “‘where two statutory provisions proscribe the “same offense,” they are construed not to authorize cumulative punishments in the absence of a clear indication of contrary legislative intent.’” (Emphasis sic.) Ruff, 143 Ohio St.3d 114 , 2015-Ohio-995 , at ¶ 11, quo | 1 | 2024–2024 |
Blockburger v. United States
green
2 sentences2022I would therefore return to comparing the offenses in the abstract to determine their import, applying the tests set forth in Blockburger, 284 U.S. 299 , 52 S.Ct. 180 , 76 L.Ed. 306 , and in this court’s early R.C. 2945.21 precedent: that is, if “the commission of one offense will necessarily result in commission of the other, then the offenses are allied offenses of similar import,” State v. Cabrales, 118 Ohio St.3d 54 , 2008-Ohio-1625 , 886 N.E.2d 181, ¶ 26 . 2022I would therefore return to comparing the offenses in the abstract to determine their import, applying the tests set forth in Blockburger, 284 U.S. 299 , 52 S.Ct. 180 , 76 L.Ed. 306 , and in this court’s early R.C. 2945.21 precedent: that is, if “the commission of one offense will necessarily result in commission of the other, then the offenses are allied offenses of similar import,” State v. Cabrales, 118 Ohio St.3d 54 , 2008-Ohio-1625 , 886 N.E.2d 181, ¶ 26 . | 1 | 2022–2022 |
| State v. McAlpin green | 1 | 2022–2022 |
| State v. Cabrales green | 1 | 2022–2022 |
| State v. Vanausdal green | 1 | 2022–2022 |
| State v. Roberts green | 1 | 2021–2021 |
| State v. Frye green | 1 | 2020–2020 |
| State v. Williams green | 1 | 2020–2020 |
| State v. Whipple green | 1 | 2020–2020 |
| State v. Glenn green | 1 | 2020–2020 |
| State v. Ishmail green | 1 | 2019–2019 |
| Morgan v. Eads green | 1 | 2019–2019 |
| State v. Miranda green | 1 | 2019–2019 |
| State v. Rucker neutral | 1 | 2019–2019 |
| State v. Williams green | 1 | 2018–2018 |
| State v. Jackson green | 1 | 2018–2018 |
| State v. Grayson green | 1 | 2018–2018 |
| State v. Stinnett neutral | 1 | 2018–2018 |
| State v. Rance green | 1 | 2017–2017 |
| State v. Lewis red | 1 | 2017–2017 |
| State v. English neutral | 1 | 2017–2017 |
| State v. Jones green | 1 | 2017–2017 |
| State v. Echols green | 1 | 2016–2016 |
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.