unsuccessful defense (Ohio) · Go Syfert
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unsuccessful defense in Ohio

64 Ohio opinions name it 4 courts 1986–2026 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 (5)

CaseFollowedCited
Miller v. Millergreen
ohioctapp · 2012 · cited in 3 Ohio opinions naming this issue, 2012–2026
2 sentences

2026Dec. 14, 2000); Miller v. Miller, 2012-Ohio-2905, ¶ 18 (5th Dist.) (“R.C. 2323.51 does not purport to punish a party for raising an unsuccessful claim.”).

2013No. 11CA020, 2012-Ohio-2905, ¶ 18 (“R.C. 2323.51 does not purport to punish a party for raising an unsuccessful claim”).

23
Strickland v. Washingtongreen
scotus · 1984 · cited in 51 Ohio opinions naming this issue, 1986–2018
2 sentences

1986In summary, I too am aware of the admonition of the United States Supreme Court that “[j]udicial scrutiny of counsel’s performance must be highly deferential.” Strickland, supra, at 689 .1 adhere to this position lest we face a proliferation of ineffectiveness claims in which “[criminal trials resolved unfavorably to the defendant would increasingly come to be followed by a second trial, this one of counsel’s unsuccessful defense.” Id. at 690 .

1986In summary, I too am aware of the admonition of the United States Supreme Court that “[j]udicial scrutiny of counsel’s performance must be highly deferential.” Strickland, supra, at 689 .1 adhere to this position lest we face a proliferation of ineffectiveness claims in which “[criminal trials resolved unfavorably to the defendant would increasingly come to be followed by a second trial, this one of counsel’s unsuccessful defense.” Id. at 690 .

151
Michel v. Louisianagreen
scotus · 1956 · cited in 3 Ohio opinions naming this issue, 2008–2026
2 sentences

2026Therefore, “a court must indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance; that is, the [claimant] must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound trial strategy.’” Strickland at 689 , quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955); see also In re Riley, 2003-Ohio-4109 , ¶ 18- 19 (4th Dist.).

2026Therefore, “a court must indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound trial strategy.’” Strickland at 689 , quoting Michel v. Louisiana, 350 U.S. 91 (1955).

13
State v. Banksgreen
ohioctapp · 2021 · cited in 1 Ohio opinions naming this issue, 2025–2025
2 sentences

2025The United States Supreme Court noted in Strickland that “it is all too tempting for a defendant to second-guess his lawyer after conviction” and likewise that it would be “all too easy for a court, examining an unsuccessful defense in hindsight, to conclude that a particular act or omission was deficient.” State v. Banks, 2021-Ohio-511, ¶ 3 (8th Dist.), citing Strickland.

2025Therefore, appellate courts are required to “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance.” Id.

11
Holmes v. Crawford Machine, Inc.green
ohio · 2012 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019See Holmes v. Crawford Mach., Inc., 134 Ohio St.3d 303 , 2012- Ohio-5380, 982 N.E.2d 643, ¶ 22 .

2019See Holmes v. Crawford Mach., Inc., 134 Ohio St.3d 303 , 2012- Ohio-5380, 982 N.E.2d 643, ¶ 22 .

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
Knutty v. Wallace green
ohioctapp · 1995
2 sentences

2018In contrast to these cases, DE was specifically found to have acted in bad faith. *1005 {¶ 131} In the context of claims under 42 U.S.C. 1988, parties are considered "prevailing for attorney fees purposes if they succeed on any significant issue in litigation that achieves some of the benefit the parties sought in bringing suit." Knutty v. Wallace , 100 Ohio App.3d 555 , 559, 654 N.E.2d 420 (10th Dist.1995).

2018In contrast to these cases, DE was specifically found to have acted in bad faith. *1005 {¶ 131} In the context of claims under 42 U.S.C. 1988, parties are considered "prevailing for attorney fees purposes if they succeed on any significant issue in litigation that achieves some of the benefit the parties sought in bringing suit." Knutty v. Wallace , 100 Ohio App.3d 555 , 559, 654 N.E.2d 420 (10th Dist.1995).

12018–2018
State ex rel. Kabatek v. Stackhouse green
ohio · 1983
2 sentences

2018Hocking No. 94CA19, 1995 WL 767921 , at *8 (no evidence of bad faith); Caspar, 53 Ohio St.3d at 20 , 558 N.E.2d 49 (because defense was partially successful, defendant did not act in bad faith); Kabatek , 6 Ohio St.3d at 56 , 451 N.E.2d 248 (the fact alone of interposing an unsuccessful defense does not demonstrate bad faith).

2018Hocking No. 94CA19, 1995 WL 767921 , at *8 (no evidence of bad faith); Caspar, 53 Ohio St.3d at 20 , 558 N.E.2d 49 (because defense was partially successful, defendant did not act in bad faith); Kabatek , 6 Ohio St.3d at 56 , 451 N.E.2d 248 (the fact alone of interposing an unsuccessful defense does not demonstrate bad faith).

12018–2018
State ex rel. Caspar v. City of Dayton green
ohio · 1990
2 sentences

2018Hocking No. 94CA19, 1995 WL 767921 , at *8 (no evidence of bad faith); Caspar, 53 Ohio St.3d at 20 , 558 N.E.2d 49 (because defense was partially successful, defendant did not act in bad faith); Kabatek , 6 Ohio St.3d at 56 , 451 N.E.2d 248 (the fact alone of interposing an unsuccessful defense does not demonstrate bad faith).

2018Hocking No. 94CA19, 1995 WL 767921 , at *8 (no evidence of bad faith); Caspar, 53 Ohio St.3d at 20 , 558 N.E.2d 49 (because defense was partially successful, defendant did not act in bad faith); Kabatek , 6 Ohio St.3d at 56 , 451 N.E.2d 248 (the fact alone of interposing an unsuccessful defense does not demonstrate bad faith).

12018–2018
Hensley v. Eckerhart green
scotus · 1983
2 sentences

2013Id. “[W]ork on an unsuccessful claim cannot be deemed to have been expended in pursuit of the ultimate result achieved.” (Internal quotations and citations omitted.) Id. at 435 .

2013Id. “[W]ork on an unsuccessful claim cannot be deemed to have been expended in pursuit of the ultimate result achieved.” (Internal quotations and citations omitted.) Id. at 435 .

12013–2013
Helfrich v. Mellon, 06-Ca-69 (6-27-2007) neutral
ohioctapp · 2007
1 sentence

2010No. 06-CA-69, 2007-Ohio-3358 , 2007 WL 1881537 , at ¶ 72-73, Ulrich ultimately prevailed on all of his claims.

12010–2010
State v. Smith, 23542 (9-28-2007) green
ohioctapp · 2007
1 sentence

2009No. 23542, 2007-Ohio-5119 . {¶ 5} On October 24, 2007, Smith filed a petition for post-conviction relief, contending that he had received ineffective assistance of trial counsel because his trial attorneys pursued an unsuccessful defense and failed to investigate or discuss with him the possibility of the defense of not guilty by reason of insanity.

12009–2009
State v. Griffin, Unpublished Decision (4-29-2004) neutral
ohioctapp · 2004
1 sentence

2008State v. Griffin , Cuyahoga App. No. 82979, 2004-Ohio-2155 , ¶ 8 , citing Strickland .

12008–2008
State v. King, Unpublished Decision (7-18-2006) green
ohioctapp · 2006
1 sentence

2008"A court must indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance, that is the defendant must overcome the presumption that under the circumstances the challenged action `might be considered sound trial strategy.'" Id., quoting Michel v. Louisiana (1955), 350 U.S. 91 , 101 . {¶ 41} Furthermore, as stated in Strickland , even if appellant establishes that an error by his counsel was professionally unreasonable under all the circumstances of the case, he must still establish prejudice, to wit: that but for the unreasonable error t

12008–2008
Commonwealth v. Bell green
pa · 1965
2 sentences

1986In the case sub judice, however, the instances of counsel’s ineffectiveness are so compelling that I must agree in this instance that “it is unfair to hang the client because of the fault of the attorney * * *.” Commonwealth v. Bell (1965), 417 Pa. 291, 297 , 208 A. 2d 465, 469 , Musmanno, J., dissenting.

1986In the case sub judice, however, the instances of counsel’s ineffectiveness are so compelling that I must agree in this instance that “it is unfair to hang the client because of the fault of the attorney * * *.” Commonwealth v. Bell (1965), 417 Pa. 291, 297 , 208 A. 2d 465, 469 , Musmanno, J., dissenting.

11986–1986

Where else courts name it

OH 64 (1986–2026) CA 35 (1978–2024) WA 24 (1978–2020) NY 21 (1960–2022) IL 15 (1903–2017) FL 14 (1979–2014) TX 14 (1983–2026) IN 11 (1993–2018) NJ 10 (1979–2025) PA 9 (1993–2024) DC 9 (1946–2018) CO 8 (1987–2026) MN 6 (1941–2025) MD 5 (1977–2015) NC 5 (1993–2020) AL 4 (1913–1988) WI 4 (1983–2015) DE 4 (1972–2025) ID 4 (1997–2023) MI 3 (1986–2023) GA 3 (2014–2017) VT 3 (2010–2025) LA 3 (1979–2024) MS 3 (2018–2021) HI 3 (2001–2008) MA 2 (1994–2008) WV 2 (1995–2008) TN 2 (1927–2013) OK 2 (1994–2013) NV 2 (1980–2007) AK 2 (1993–1994) ND 2 (1992–2026) UT 2 (1990–2010)

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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