misconduct claim (Ohio) · Go Syfert
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misconduct claim in Ohio

8 Ohio opinions name it 2 courts 2006–2026 5 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
Maggio v. City of Clevelandgreen
· 1949 · cited in 5 Ohio opinions naming this issue, 2024–2026
2 sentences

2026“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. -14- Case No. 17-24-12 {¶33} In closing statements, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

2026“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. -14- Case No. 17-24-12 {¶33} In closing statements, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

25
State v. Smithgreen
ohio · 1984 · cited in 2 Ohio opinions naming this issue, 2025–2026
2 sentences

2026“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. -14- Case No. 17-24-12 {¶33} In closing statements, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

2026“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. -14- Case No. 17-24-12 {¶33} In closing statements, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

22
Drake v. Caterpillar Tractor Co.green
ohio · 1984 · cited in 2 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See Maggio v. Cleveland, 151 Ohio St. 136, 140-41 (1949) (regarding opening statements); Drake v. Caterpillar Tractor Co., 15 Ohio St.3d 346, 347-48 (1984) (applying the holding in Maggio to closing arguments).

2024See Maggio v. Cleveland, 151 Ohio St. 136, 140-41 (1949) (regarding opening statements); Drake v. Caterpillar Tractor Co., 15 Ohio St.3d 346, 347-48 (1984) (applying the holding in Maggio to closing arguments).

22

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 (5)

CaseCitedYears
State v. Nicholson green
ohio · 2024
2 sentences

2026“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. -14- Case No. 17-24-12 {¶33} In closing statements, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

2026“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. -14- Case No. 17-24-12 {¶33} In closing statements, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

12026–2026
State v. Noling green
ohio · 2002
1 sentence

2025“And unless it appears that counsel ‘deliberately attempt[ed] to influence and sway the jury by a recital of matters foreign to the case,’ remarks made during opening statements cannot form the basis of a misconduct claim.” Id., quoting Maggio v. Cleveland, 151 Ohio St. 136 (1949), paragraph two of the syllabus. {¶42} In closing arguments, “[t]he prosecution is normally entitled to a certain degree of latitude.” Smith, 14 Ohio St.3d at 13-14 (identifying types of remarks to be avoided).

12025–2025
State v. Mammone (Slip Opinion) green
ohio · 2014
2 sentences

2016“If the evidence was properly admitted, then the prosecutor’s decision to offer it cannot form the basis of a misconduct claim.” Mammone, 139 Ohio St.3d 467 , 2014-Ohio- 1942, 13 N.E.3d 1051, at ¶ 116 . 13.

2016“If the evidence was properly admitted, then the prosecutor’s decision to offer it cannot form the basis of a misconduct claim.” Mammone, 139 Ohio St.3d 467 , 2014-Ohio- 1942, 13 N.E.3d 1051, at ¶ 116 . 13.

12016–2016
State v. Spencer neutral
ohioctapp · 1997
1 sentence

2016Id.

12016–2016
City of Akron v. Davenport, Unpublished Decision (2-4-2004) green
ohioctapp · 2004
1 sentence

2006In the context of considering what constitutes "filing" for purposes of considering an appeal from a conviction for making false allegations of a peace officer's misconduct in violation of R.C. 2921.15 , the Ninth District Court of Appeals observed: "Webster's Revised Unabridged Dictionary (1913) 559, defines `file' as: `To bring before a court or legislative body by presenting proper papers in a regular way[.]'" Akron v. Davenport, Summit App. No. 21552, 2004-Ohio-435 , at ¶ 17. {¶ 10} Certainly, imprinting a formal date stamp is the "regular way" of filing for courts and most administrative

12006–2006

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2921.04 (3) OH § Ohio Rev. Code § 2941.145 (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

CA 142 (1918–2026) NY 13 (1916–2022) IA 12 (1991–2025) PA 12 (2004–2025) TN 10 (1986–2024) MI 8 (1959–2025) MO 8 (1991–2022) OH 8 (2006–2026) IL 7 (1998–2017) WA 7 (1915–2017) KS 7 (1994–2020) MN 6 (1985–2016) CT 6 (1973–2004) TX 5 (1983–2013) OK 5 (1980–2014) AK 4 (2013–2025) DC 4 (2010–2017) FL 4 (1987–2023) IN 4 (1994–2025) MD 3 (1987–2000) UT 3 (1983–2017) NC 3 (2003–2020) AR 2 (2008–2010) NV 2 (2015–2015) HI 2 (1999–2012) SD 2 (1985–1993) CO 2 (2007–2022) OR 2 (1981–1994) SC 2 (2001–2015) WY 2 (1993–2016) DE 2 (2015–2019) VA 2 (1979–2015) AL 2 (1981–2010) MT 2 (1998–1999) AZ 2 (1997–2016)

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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