challenge doctrine (Ohio) · Go Syfert
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challenge doctrine in Ohio

9 Ohio opinions name it 2 courts 1983–2021 1 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 (3)

CaseFollowedCited
State v. Adams, Unpublished Decision (7-28-2005)green
ohioctapp · 2005 · cited in 1 Ohio opinions naming this issue, 2021–2021
2 sentences

2021Cuyahoga No. 85267, 2005-Ohio-3837, ¶ 5 (concluding a challenge to the waiver of counsel was moot after defendant’s 30-day suspended sentence and term of probation for a petty offense had expired). {¶12} The first assigned error is without merit. {¶13} Appellant next argues the trial court erred when it allowed Brian McCauley, admittedly diagnosed with paranoid schizophrenia, to testify over appellant’s challenge to his competency. {¶14} Evidence Rule 601, the general rule of competency, provides in pertinent part as follows: (A) General Rule.

2021Cuyahoga No. 85267, 2005-Ohio-3837, ¶ 5 (concluding a challenge to the waiver of counsel was moot after defendant’s 30-day suspended sentence and term of probation for a petty offense had expired). {¶12} The first assigned error is without merit. {¶13} Appellant next argues the trial court erred when it allowed Brian McCauley, admittedly diagnosed with paranoid schizophrenia, to testify over appellant’s challenge to his competency. {¶14} Evidence Rule 601, the general rule of competency, provides in pertinent part as follows: (A) General Rule.

11
Bowen v. Roygreen
scotus · 1986 · cited in 1 Ohio opinions naming this issue, 1996–1996
2 sentences

1996See, generally, id. at 701-712 , 106 S.Ct. at 2153-2159 , 90 L.Ed.2d at 745-753 (Burger, C.J., joined by Powell and Rehnquist, JJ.).

1996See, generally, id. at 701-712 , 106 S.Ct. at 2153-2159 , 90 L.Ed.2d at 745-753 (Burger, C.J., joined by Powell and Rehnquist, JJ.).

11
State v. Jacksongreen
ohio · 1980 · cited in 1 Ohio opinions naming this issue, 1983–1983
2 sentences

1983As was expressed in my dissenting opinion in State v. Jackson (1980), 64 Ohio St. 2d 107, 114-115 [ 18 O.O.3d 348 ], when a facially sufficient constitutional claim is dependent upon factual allegations that could not be determined on the basis of the files and records included in a challenge because the claim is dependent upon evidence outside the record, a hearing pursuant to R.C. 2953.21(E), or a summary judgment proceeding pursuant to R.C. 2953.21(D), is necessary to dispose of the petition.

1983As was expressed in my dissenting opinion in State v. Jackson (1980), 64 Ohio St. 2d 107, 114-115 [ 18 O.O.3d 348 ], when a facially sufficient constitutional claim is dependent upon factual allegations that could not be determined on the basis of the files and records included in a challenge because the claim is dependent upon evidence outside the record, a hearing pursuant to R.C. 2953.21(E), or a summary judgment proceeding pursuant to R.C. 2953.21(D), is necessary to dispose of the petition.

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 (7)

CaseCitedYears
State v. Gwynne (Slip Opinion) green
ohio · 2019
1 sentence

2020Thus, this challenge requires an analysis used in Marcum, infra, not the consecutive sentence review used in State v. Gwynne, 158 Ohio St.3d 279 , 2019-Ohio-4761 , 141 N.E.3d 169 , ¶ 15-17.

12020–2020
Hernandez v. New York green
scotus · 1991
1 sentence

2012The Court 14 concluded that the prosecutor offered a race-neutral basis for the peremptory strikes because he “explained that the specific responses and the demeanor of the two individuals during voir dire caused him to doubt their ability to defer to the official translation of Spanish-language testimony.” Id. at 360 . {¶37} In the case at hand, although the trial court mentioned Batson, it is clear from the record that it properly reviewed the challenge under the challenge-for-cause standard.

12012–2012
State v. Cook green
ohio · 1998
1 sentence

2009Cook , supra. {¶ 63} In rejecting the challenge as being in violation of the Retroactivity Clause, the Court in Cook stated that many of the law's requirements were "directed towards officials rather than offenders"; the registration requirements were "` de minimis ' procedural requirements that are necessary to achieve the goals of R.C.

12009–2009
Carver v. the Township of Deerfield green
ohioctapp · 2000
1 sentence

2008In re Dismissal of Osborn , 1992 WL 214527 (Ohio App. 5 Dist.); Carver v. Deerfield Township (2000), 139 Ohio App.3d 64 . {¶ 19} Appellee Riggs contests the claim of privilege by arguing that upon the circumstances of this case, the attorney-client privilege relationship does not exist as to the non-lawyer witnesses. {¶ 20} In the unique posture of this case — a limited, focused interlocutory appeal of a denial of summary judgment — we conclude the question of privilege is properly left to the discretion of the trial court.

12008–2008
Kovacs v. Kovacs green
mdctspecapp · 1993
2 sentences

2001“As the representative of the State, the [court’s] responsibility to ensure the best interests of the children supersedes that of the parents.” Id. at 301 , 633 A.2d at 431 . {¶ 16} Finally, appellant argues that because appellee could have mounted a challenge to the arbitration clause in a previous action, she is now barred from bringing this challenge under the doctrine of res judicata.

2001“As the representative of the State, the [court’s] responsibility to ensure the best interests of the children supersedes that of the parents.” Id. at 301 , 633 A.2d at 431 . {¶ 16} Finally, appellant argues that because appellee could have mounted a challenge to the arbitration clause in a previous action, she is now barred from bringing this challenge under the doctrine of res judicata.

12001–2001
Grava v. Parkman Township green
ohio · 1995
2 sentences

2001This argument, too, lacks merit. {¶ 17} Under the doctrine of res judicata, “[a] valid, final judgment rendered upon the merits bars all subsequent actions based upon any claim arising out of the transaction or occurrence that was the subject matter of the previous action.” Grava v. Parkman Twp. (1995), 73 Ohio St.3d 379 , 653 N.E.2d 226 , syllabus.

2001This argument, too, lacks merit. {¶ 17} Under the doctrine of res judicata, “[a] valid, final judgment rendered upon the merits bars all subsequent actions based upon any claim arising out of the transaction or occurrence that was the subject matter of the previous action.” Grava v. Parkman Twp. (1995), 73 Ohio St.3d 379 , 653 N.E.2d 226 , syllabus.

12001–2001
City of Defiance v. Kretz green
ohio · 1991
1 sentence

1998In City of Defiance v. Kretz (1991), 60 Ohio St.3d 1 , the Ohio Supreme Court held: a motion to suppress is a proper pre-trial procedure for challenging the breathalyzer test results when the defendant is charged with a violation of R.C. 4511.19 (A)(3).

11998–1998

Where else courts name it

CA 42 (1978–2025) OR 23 (2000–2025) IN 20 (1976–2014) WA 20 (1941–2025) NY 18 (1940–2026) TX 16 (1997–2023) UT 16 (2004–2020) PA 15 (1974–2026) MI 13 (1978–2025) IL 11 (1951–2024) IA 11 (1974–2024) OH 9 (1983–2021) MO 9 (1967–2024) MA 8 (1986–2026) WI 7 (2004–2019) FL 7 (1990–2016) NC 6 (2013–2020) VA 6 (1991–2016) CO 6 (1995–2025) KS 5 (2016–2019) MT 5 (1931–2011) DC 4 (1997–2024) GA 3 (1984–2018) OK 3 (1987–2001) CT 3 (1977–1997) LA 3 (1994–2014) SD 3 (1977–1992) DE 3 (2016–2023) MD 2 (1997–2000) AZ 2 (2000–2019) MS 2 (1986–2026) NH 2 (1983–2016) AR 2 (2001–2003) NE 2 (1974–1983) AL 2 (1991–2017) ND 2 (1988–2023) RI 2 (2012–2012) AK 2 (1988–2020) NJ 2 (2009–2012) NM 2 (1990–2012)

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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