capacity to understand warning (Ohio) · Go Syfert
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capacity to understand warning in Ohio

8 Ohio opinions name it 2 courts 2011–2023 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 (1)

CaseFollowedCited
State v. Whisenantgreen
ohioctapp · 1998 · cited in 1 Ohio opinions naming this issue, 2013–2013
1 sentence

2013Relevant circumstances in our inquiry include “age, experience, education, background, and intelligence” of the suspect, as well as “whether he has the capacity to understand warnings given him, the nature of his Fifth Amendment rights, and the consequences of waiving those rights.” Fare v. Michael C., 442 U.S. 707, 725 , 99 S.Ct. 2560 (1979); see also State v. Whisenant, 127 Ohio App.3d 75, 87 (11th Dist. 1998) (stating that suspect’s previous criminal experience is also a relevant circumstance).

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 (4)

CaseCitedYears
Fare v. Michael C. green
scotus · 1979
2 sentences

2016“Relevant circumstances in our inquiry include ‘age, experience, education, background, and intelligence’ of the suspect, as well as ‘whether he has the capacity to understand warnings given him, the nature of his Fifth Amendment -10- Case No. 12-15-11 rights, and the consequences of waiving those rights.’ ” Id., quoting Fare v. Michael C., 442 U.S. 707, 725 , 99 S.Ct. 2560 , 61 L.Ed.2d 197 (1979).

2016“Relevant circumstances in our inquiry include ‘age, experience, education, background, and intelligence’ of the suspect, as well as ‘whether he has the capacity to understand warnings given him, the nature of his Fifth Amendment -10- Case No. 12-15-11 rights, and the consequences of waiving those rights.’ ” Id., quoting Fare v. Michael C., 442 U.S. 707, 725 , 99 S.Ct. 2560 , 61 L.Ed.2d 197 (1979).

52011–2016
State v. Barker (Slip Opinion) green
ohio · 2016
2 sentences

2020The court stated as follows: The totality approach permits—indeed, it mandates—inquiry into all the circumstances surrounding the interrogation, [including] evaluation of the juvenile's age, experience, education, background, and intelligence, and into whether he has the capacity to understand the warnings given him, the nature of his Fifth Amendment rights, and the consequences of waiving those rights. * * * “ ‘It is now commonly recognized that courts should take “special care” in scrutinizing a purported confession or waiver by a child.’ ” When an admission is obtained from a juvenile witho

2020The court stated as follows: The totality approach permits—indeed, it mandates—inquiry into all the circumstances surrounding the interrogation, [including] evaluation of the juvenile's age, experience, education, background, and intelligence, and into whether he has the capacity to understand the warnings given him, the nature of his Fifth Amendment rights, and the consequences of waiving those rights. * * * “ ‘It is now commonly recognized that courts should take “special care” in scrutinizing a purported confession or waiver by a child.’ ” When an admission is obtained from a juvenile witho

32020–2023
State v. Ford (Slip Opinion) green
ohio · 2019
1 sentence

2023State v. Barker, 149 Ohio St.3d 1 , 2016-Ohio-2708 , 73 N.E.3d 365, ¶ 24 . {¶ 25} “[D]eficient intelligence is but one factor in the totality of the circumstances that must be considered in determining the voluntariness of a waiver.” State v. Ford, 158 Ohio St.3d 139 , 2019-Ohio-4539 , 140 N.E.3d 616 , ¶ 190.

12023–2023
State v. Gumm green
ohio · 1995
1 sentence

2016“Relevant circumstances in our inquiry include ‘age, experience, education, background, and intelligence’ of the suspect, as well as ‘whether he has the capacity to understand warnings given him, the nature of his Fifth Amendment -10- Case No. 12-15-11 rights, and the consequences of waiving those rights.’ ” Id., quoting Fare v. Michael C., 442 U.S. 707, 725 , 99 S.Ct. 2560 , 61 L.Ed.2d 197 (1979).

12016–2016

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2907.02 (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

CT 34 (1986–2025) CA 24 (1980–2026) VA 18 (1988–2026) AL 12 (1984–2010) NY 9 (1980–2024) MS 9 (1994–2024) OH 8 (2011–2023) LA 8 (1998–2018) DC 8 (1991–2015) FL 8 (1985–2016) IL 7 (1990–2024) MI 7 (1984–2025) TX 6 (2007–2025) ID 6 (1997–2019) MD 6 (1987–2026) SD 5 (1984–2014) WA 5 (1980–2020) NC 5 (2018–2022) VT 5 (1987–1994) AR 4 (1992–2006) WV 4 (1985–2024) WY 4 (1984–2013) RI 3 (1980–2013) GA 2 (2022–2023) MN 2 (1985–2005) PR 2 (1989–2003) ME 2 (1979–1982) ND 2 (1981–1990) PA 2 (1982–1983) NE 2 (2015–2016) TN 2 (1997–1998)

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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