criminal defendant seeking challenge (Ohio) · Go Syfert
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criminal defendant seeking challenge in Ohio

65 Ohio opinions name it 2 courts 1996–2025 11 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 (5)

CaseFollowedCited
State v. Calhoungreen
ohio · 1999 · cited in 39 Ohio opinions naming this issue, 1999–2025
2 sentences

2025Relevant here is R.C. 2953.21(A)(1)(a)(i), which states that “[a]ny person who has been convicted of a criminal offense or adjudicated a delinquent child and who claims that there was such a denial or infringement of the person’s rights as to render the judgment void or voidable under the Ohio Constitution or the Constitution of the United States” “may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the court to vacate or set aside the judgment or sentence or to grant other appropriate relief[.]” {¶15} “A criminal defendant seeking to

2025Relevant here is R.C. 2953.21(A)(1)(a)(i), which provides as follows: (A)(1)(a) A person in any of the following categories may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the court to vacate or set aside the judgment or sentence or to grant other appropriate relief: Pickaway App. No. 24CA26 7 (i) Any person who has been convicted of a criminal offense or adjudicated a delinquent child and who claims that there was such a denial or infringement of the person's rights as to render the judgment void or voidable under the Ohio Constit

939
State v. Colegreen
ohio · 1982 · cited in 46 Ohio opinions naming this issue, 1999–2025
2 sentences

2020(F) Unless the petition and the files and records of the case show the petitioner is not entitled to relief, the court shall proceed to a prompt hearing on the issues even if a direct appeal of the case is pending. * * * (H) If the court does not find grounds for granting relief, it shall make and file findings of fact and conclusions of law and shall enter judgment denying relief on the petition. * * * 5 {¶15} “According to the postconviction relief statute, a criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a

2019Accordingly, "a criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing." State v. Calhoun, 86 Ohio St.3d 279, 282 (1999), citing State v. Cole, 2 Ohio St.3d 112 (1982).

646
State v. Ludwickgreen
ohioctapp · 2023 · cited in 2 Ohio opinions naming this issue, 2025–2025
2 sentences

2025Relevant here is R.C. 2953.21(A)(1)(a)(i), which states that “[a]ny person who has been convicted of a criminal offense or adjudicated a delinquent child and who claims that there was such a denial or infringement of the person’s rights as to render the judgment void or voidable under the Ohio Constitution or the Constitution of the United States” “may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the court to vacate or set aside the judgment or sentence or to grant other appropriate relief[.]” {¶15} “A criminal defendant seeking to

2025Relevant here is R.C. 2953.21(A)(1)(a)(i), which provides as follows: (A)(1)(a) A person in any of the following categories may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the court to vacate or set aside the judgment or sentence or to grant other appropriate relief: Pickaway App. No. 24CA26 7 (i) Any person who has been convicted of a criminal offense or adjudicated a delinquent child and who claims that there was such a denial or infringement of the person's rights as to render the judgment void or voidable under the Ohio Constit

22
State v. Barrongreen
ohioctapp · 2023 · cited in 2 Ohio opinions naming this issue, 2025–2025
2 sentences

2025R.C. 2953.21 “provides three methods for adjudicating the petition.” State v. Barron, 2023-Ohio-1249, ¶ 9 (12th Dist.). “[T]he trial court may (1) summarily dismiss the petition without holding an evidentiary hearing, (2) grant summary judgment on the petition to either party who moved for summary judgment, or (3) hold an evidentiary hearing on the issues raised by the petition.” Id., citing R.C. 2953.21(D)-(F). {¶16} Before granting a hearing, the court “shall determine whether there are substantive grounds for relief.” R.C. 2953.21(D).

2025R.C. 2953.21 “provides three methods for adjudicating the petition.” State v. Barron, 2023-Ohio-1249, ¶ 9 (12th Dist.). [T]he trial court may (1) summarily dismiss the petition without holding an evidentiary hearing, (2) grant summary judgment on the petition to either party who moved for summary judgment, or (3) hold an evidentiary hearing on the issues raised by the petition.

22
State v. Calhoungreen
ohio · 1999 · cited in 4 Ohio opinions naming this issue, 2008–2024
2 sentences

2011See R.C. 2953.21(A)(1); State v. Calhoun, 86 Ohio St.3d 279 , 283, 1999-Ohio-102 . {¶10} A criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing.

2009Even if his allegations were *Page 3 conclusory, Lenoir claims he was entitled to a hearing to flesh them out. {¶ 10} Under R.C. 2953.21 , "a criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing." State v. Calhoun , 86 Ohio St.3d 279 , 282 , 1999-Ohio-102 , citing State v. Cole (1982), 2 Ohio St.3d 112 .

14

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 (12)

CaseCitedYears
State v. Apanovitch (Slip Opinion) green
ohio · 2018
2 sentences

2023“This means that any right to postconviction relief must arise from the statutory scheme enacted by the General Assembly.” State v. Apanovitch, 155 Ohio St.3d 358 , 2018-Ohio-4744 , 121 N.E.3d 351, ¶ 35 . {¶15} A criminal defendant seeking to challenge a conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.

2023“This means that any right to postconviction relief must arise from the statutory scheme enacted by the General Assembly.” State v. Apanovitch, 155 Ohio St.3d 358 , 2018-Ohio-4744 , 121 N.E.3d 351, ¶ 35 . {¶15} A criminal defendant seeking to challenge a conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.

32019–2023
State v. Jackson green
ohio · 1980
2 sentences

2022Scioto App. No. 22CA3978 6 {¶16} “In a petition for post-conviction relief, which asserts ineffective assistance of counsel, the petitioner bears the initial burden to submit evidentiary documents containing sufficient operative facts to demonstrate the lack of competent counsel and that the defense was prejudiced by counsel's ineffectiveness.” State v. Jackson, 64 Ohio St. 2d 107 , 413 N.E.2d 819 (1980) at the syllabus. {¶17} “A criminal defendant seeking to challenge a conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.” State v. J

2022Scioto App. No. 22CA3978 6 {¶16} “In a petition for post-conviction relief, which asserts ineffective assistance of counsel, the petitioner bears the initial burden to submit evidentiary documents containing sufficient operative facts to demonstrate the lack of competent counsel and that the defense was prejudiced by counsel's ineffectiveness.” State v. Jackson, 64 Ohio St. 2d 107 , 413 N.E.2d 819 (1980) at the syllabus. {¶17} “A criminal defendant seeking to challenge a conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.” State v. J

31996–2022
Pons v. Ohio State Medical Board green
ohio · 1993
2 sentences

2009Bd. (1993), 66 Ohio St.3d 619 , 621 . {¶ 9} A criminal defendant seeking to challenge his conviction through a petition for post-conviction relief is not automatically entitled to a hearing.

2006Bd. (1993), 66 Ohio St.3d 619 , 621 . {¶ 19} A criminal defendant seeking to challenge his conviction through a petition for post-conviction relief is not automatically entitled to a hearing.

22006–2009
State v. Burke neutral
ohioctapp · 2020
1 sentence

2023Trumbull No. 2020-T-0013, 2020-Ohio-5474, ¶ 15 , quoting Calhoun at 282, citing State v. Cole, 2 Ohio St.3d 112 , 443 N.E.2d 169 (1982). “‘Before granting an evidentiary hearing on the petition, the trial court shall determine whether there are substantive grounds for relief[.]’” (Emphasis omitted.) Burke at ¶ 15, quoting Calhoun at 282-283 . {¶17} R.C. 2953.21, Ohio’s postconviction relief statute, states, in pertinent part: (A)(1)(a) A person in any of the following categories may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the c

12023–2023
Darby v. A-Best Products Co. green
ohio · 2004
2 sentences

2020Co., 102 Ohio St.3d 410 , 2004-Ohio-3720 , 811 N.E.2d 1117, ¶ 13 . {¶ 18} A criminal defendant seeking to challenge a conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.

2020Co., 102 Ohio St.3d 410 , 2004-Ohio-3720 , 811 N.E.2d 1117, ¶ 13 . {¶ 18} A criminal defendant seeking to challenge a conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.

12020–2020
State v. Milanovich green
ohio · 1975
2 sentences

2017State v. Milanovich, 42 Ohio St.2d 46, 50 , 325 N.E.2d 540 (1975). {¶11} Under R.C. 2953.21, a criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing.

2017State v. Milanovich, 42 Ohio St.2d 46, 50 , 325 N.E.2d 540 (1975). {¶11} Under R.C. 2953.21, a criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing.

12017–2017
In re H.V. green
ohio · 2014
2 sentences

2016V., 138 Ohio St.3d 408 , 2014-Ohio-812 , 7 N.E.3d 1173, ¶ 8 . {¶13} A criminal defendant seeking to challenge a conviction through a petition for post-conviction relief is not automatically entitled to an evidentiary hearing.

2016V., 138 Ohio St.3d 408 , 2014-Ohio-812 , 7 N.E.3d 1173, ¶ 8 . {¶13} A criminal defendant seeking to challenge a conviction through a petition for post-conviction relief is not automatically entitled to an evidentiary hearing.

12016–2016
Cullen v. State Farm Mutual Automobile Insurance green
ohio · 2013
2 sentences

2016Co., 137 Ohio St.3d 373 , 2013-Ohio-4733 , 999 N.E.2d 614, ¶ 19 . {¶10} A criminal defendant seeking to challenge the conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.

2016Co., 137 Ohio St.3d 373 , 2013-Ohio-4733 , 999 N.E.2d 614, ¶ 19 . {¶10} A criminal defendant seeking to challenge the conviction through a petition for postconviction relief is not automatically entitled to an evidentiary hearing.

12016–2016
State v. Gapen, Unpublished Decision (1-31-2005) green
ohioctapp · 2005
1 sentence

2016First, the trial court must determine whether there are substantive grounds for relief, i.e., “whether there are grounds to believe that ‘there was such a denial or infringement of the person's rights as to render the judgment void or voidable under the Ohio Constitution or the Constitution of the United States.’ ” Id. at 283, -12- quoting R.C. 2953.21(A)(1). * * * The post-conviction relief statute imposes on a petitioner “the initial burden to submit evidentiary documents containing operative facts sufficient to demonstrate substantive grounds for relief that merit a hearing.” State v. Gapen

12016–2016
State v. Perry green
ohio · 1967
1 sentence

2004State v. Perry (1967), 10 Ohio St.2d 175 . {¶ 13} A criminal defendant seeking to challenge his conviction through a petition for post-conviction relief is not automatically entitled to a hearing.

12004–2004
State v. Adams green
ohio · 1980
2 sentences

2003State v. Adams (1980), 62 Ohio St.2d 151 , 157 , 16 O.O.3d 169, 172-173 , 404 N.E.2d 144 , 148-149 ; State v. Keenan (1998), 81 Ohio St.3d 133 , 137 , 689 N.E.2d 929 , 937." {¶ 24} A criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing to review the petition.

2003State v. Adams (1980), 62 Ohio St.2d 151 , 157 , 16 O.O.3d 169, 172-173 , 404 N.E.2d 144 , 148-149 ; State v. Keenan (1998), 81 Ohio St.3d 133 , 137 , 689 N.E.2d 929 , 937." {¶ 24} A criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing to review the petition.

12003–2003
State v. Keenan green
ohio · 1998
2 sentences

2003State v. Adams (1980), 62 Ohio St.2d 151 , 157 , 16 O.O.3d 169, 172-173 , 404 N.E.2d 144 , 148-149 ; State v. Keenan (1998), 81 Ohio St.3d 133 , 137 , 689 N.E.2d 929 , 937." {¶ 24} A criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing to review the petition.

2003State v. Adams (1980), 62 Ohio St.2d 151 , 157 , 16 O.O.3d 169, 172-173 , 404 N.E.2d 144 , 148-149 ; State v. Keenan (1998), 81 Ohio St.3d 133 , 137 , 689 N.E.2d 929 , 937." {¶ 24} A criminal defendant seeking to challenge his conviction through a petition for postconviction relief is not automatically entitled to a hearing to review the petition.

12003–2003

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2953.21 (38) OH § Ohio Rev. Code § 2907.02 (7) OH § Ohio Rev. Code § 2953.23 (5) OH § Ohio Rev. Code § 2923.02 (3) OH § Ohio Rev. Code § 2925.11 (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 65 (1996–2025) GA 7 (2015–2018) PA 2 (2000–2014)

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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