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

56 Ohio opinions name it 2 courts 1982–2026 18 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 (21)

CaseFollowedCited
State v. Harper (Slip Opinion)green
ohio · 2020 · cited in 3 Ohio opinions naming this issue, 2020–2024
2 sentences

2021Lake No. 2017-L-038, 2017-Ohio-7963 , ¶ 8 (“an appellate court’s standard of review on the denial of a motion to vacate void judgment is de novo”). {¶8} “A defendant’s ability to challenge an entry at any time is the very essence of an entry being void, not voidable.” (Citation omitted.) State v. Harper, 160 Ohio St.3d 480 , 2020-Ohio-2913 , 159 N.E.3d 248, ¶ 18 .

2021Lake No. 2017-L-038, 2017-Ohio-7963 , ¶ 8 (“an appellate court’s standard of review on the denial of a motion to vacate void judgment is de novo”). {¶8} “A defendant’s ability to challenge an entry at any time is the very essence of an entry being void, not voidable.” (Citation omitted.) State v. Harper, 160 Ohio St.3d 480 , 2020-Ohio-2913 , 159 N.E.3d 248, ¶ 18 .

13
Wells Fargo Bank, N.A. v. Scottgreen
ohioctapp · 2015 · cited in 2 Ohio opinions naming this issue, 2024–2025
2 sentences

2025“Although the lender is required to establish standing in order to meet its burden of proof in a foreclosure action, the borrower’s ability to challenge standing by attacking the assignment is limited.” Wells Fargo Bank, N.A. v. Scott, 2015-Ohio-3269, ¶ 17 (2d Dist.).

2024Montgomery No. 26552, 2015-Ohio-3269, ¶ 17 .

12
City of Huber Heights v. Dutygreen
ohioctapp · 1985 · cited in 2 Ohio opinions naming this issue, 2001–2017
2 sentences

2017See, e.g., Huber Heights v. Duty, 27 Ohio App.3d 244 (2d Dist.1985) (declining to reach merits of trial court's failure to grant motion to suppress where defendant entered guilty pleas to offenses); State v. McPherson, 8th Dist.

2001State v. Elliott (1993), 86 Ohio App.3d 792 , 795 ; Huber Hts. v. Duty (1985), 27 Ohio App.3d 244 , syllabus; State v. Lewis (Dec. 19, 1997), Trumbull App. No. 96-T-5522, unreported, 1997 WL 799537 , at fn. 1.

12
State v. Brooksgreen
ohioctapp · 2025 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026State v. Brooks, 2025-Ohio-3292, ¶ 7 (2d Dist.).

11
In re E.E.D.green
ohioctapp · 2022 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See In re E.E.D., 2022-Ohio-4014, ¶ 48-49 (8th Dist.).

11
State v. Selfgreen
ohio · 1990 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024State v. Self, 56 Ohio St.3d 73, 81 (1990).

11
State v. Kelleygreen
ohio · 1991 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024In support of its waiver argument, the State cites cases in which this court and the Ohio Supreme Court have held that a voluntary guilty plea in adult court waives the ability to challenge the ruling on a pretrial suppression motion, State v. Obermiller, 2016-Ohio-1594, ¶ 56 , to claim his or her statutory speedy trial rights were violated, State v. Kelley, 57 Ohio St.3d 127, 130 (1991), or to claim ineffective assistance of counsel, unless the plea was induced by that ineffective assistance, State v. Geraci, 2015-Ohio-2699 , ¶ 14 (8th Dist.).

11
United States v. Michael L. Meekergreen
ca6 · 2005 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023It also cited to the Sixth Circuit Court of Appeals’ decision in U.S. v. Meeker, 411 F.3d 736, 742 (6th Cir.2005), where the court pointed out that “not having, before the sentencing hearing, emotional-impact evidence from a victim ultimately matters little because the defendant cannot really rebut the evidence.” Shackleford at ¶ 25, citing Meeker at 742 .

11
State ex rel. Allen Cty. Children Servs. Bd. v. Mercer Cty. Common Pleas Court, Probate Div. (Slip Opinion)green
ohio · 2016 · cited in 1 Ohio opinions naming this issue, 2023–2023
2 sentences

2023And by “parentage,” we meant biological parentage, because paternity “affect[s] the probate court’s ability to rule on the concurrent adoption petitions.” (Emphasis sic.) Id. at ¶ 35; see also Allen Cty., 150 Ohio St.3d 230 , 2016-Ohio-7382 , 81 N.E.3d 380, at ¶ 38 (“Pushcar required the probate court to refrain from proceeding while there was a question of parentage—i.e., paternity—pending in the juvenile court” [emphasis sic]).

2023And by “parentage,” we meant biological parentage, because paternity “affect[s] the probate court’s ability to rule on the concurrent adoption petitions.” (Emphasis sic.) Id. at ¶ 35; see also Allen Cty., 150 Ohio St.3d 230 , 2016-Ohio-7382 , 81 N.E.3d 380, at ¶ 38 (“Pushcar required the probate court to refrain from proceeding while there was a question of parentage—i.e., paternity—pending in the juvenile court” [emphasis sic]).

11
Costello v. United Statesgreen
scotus · 1956 · cited in 1 Ohio opinions naming this issue, 2022–2022
2 sentences

2022See, e.g., Costello v. United States, 350 U.S. 359, 362 , 76 S.Ct. 406 , 100 L.Ed. 397 (1956). “[A]n indictment ‘fair upon its face,’ and returned by a ‘properly constituted grand jury,’ ” we have explained, “conclusively determines the existence of probable cause” to believe the defendant perpetrated the offense alleged.

2022See, e.g., Costello v. United States, 350 U.S. 359, 362 , 76 S.Ct. 406 , 100 L.Ed. 397 (1956). “[A]n indictment ‘fair upon its face,’ and returned by a ‘properly constituted grand jury,’ ” we have explained, “conclusively determines the existence of probable cause” to believe the defendant perpetrated the offense alleged.

11
State ex rel. Youngstown v. Mahoning Cty. Bd. of Elections (Slip Opinion)green
ohio · 2015 · cited in 1 Ohio opinions naming this issue, 2017–2017
2 sentences

2017See Youngstown , 144 Ohio St.3d 239 , 2015-Ohio-3761 , 41 N.E.3d 1229 , at ¶ 11. {¶ 52} Finally, the BOE objects to language in the proposed amendments purporting to limit the ability to challenge the amendments; the BOE calls these "administrative" provisions.

2017See Youngstown , 144 Ohio St.3d 239 , 2015-Ohio-3761 , 41 N.E.3d 1229 , at ¶ 11. {¶ 52} Finally, the BOE objects to language in the proposed amendments purporting to limit the ability to challenge the amendments; the BOE calls these "administrative" provisions.

11
State v. Cartergreen
ohioctapp · 1997 · cited in 1 Ohio opinions naming this issue, 2017–2017
1 sentence

2017No. 05AP-982, 2006-Ohio-3144, ¶ 14 , quoting State v. Carter, 124 Ohio App.3d 423, 429 (2d Dist.1997) ("An Alford plea is 'merely a species of a guilty plea, having the effect of waiving [a defendant's] right to appeal.' "). {¶ 10} In arguing appellant waived the right to raise the issues presented on appeal, the state relies on case law generally holding that a plea of guilty waives a defendant's ability to challenge the denial of pretrial motions.

11
State v. South (Slip Opinion)green
ohio · 2015 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
State ex rel. Newton v. Court of Claimsgreen
ohio · 1995 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
DiGiorgio v. City of Clevelandgreen
ohioctapp · 2011 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
Supportive Solutions Training Academy, L.L.C. v. Elec. Classroom of Tomorrowgreen
ohioctapp · 2012 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
State v. Paynegreen
ohio · 2007 · cited in 1 Ohio opinions naming this issue, 2010–2010
11
State v. Pasqualonegreen
ohio · 2009 · cited in 1 Ohio opinions naming this issue, 2010–2010
11
State v. McCauslandgreen
ohio · 2009 · cited in 1 Ohio opinions naming this issue, 2010–2010
11
United States v. Cottongreen
scotus · 2002 · cited in 1 Ohio opinions naming this issue, 2008–2008
11
Pratts v. Hurleygreen
ohio · 2004 · cited in 1 Ohio opinions naming this issue, 2008–2008
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Patrick (Slip Opinion)green
ohio · 2020 · cited in 1 Ohio opinions naming this issue, 2023–2023
2 sentences

2023But see State v. Patrick, 164 Ohio St.3d 309 , 2020-Ohio-6803 , 172 N.E.3d 952, ¶ 1-2, 22 (constitutional challenge to sentence could be maintained despite prohibition against appellate review in R.C. 2953.08(D)(3)).2 R.C. 2953.08(D)(1)’s limitation on a defendant’s ability to challenge a jointly recommended sentence on appeal applies to sentences imposed pursuant to plea agreements involving an agreed specific term, plea agreements involving a jointly recommended sentencing range and plea agreements involving pleas to multiple offenses with a jointly recommended aggregate sentencing range.

2023But see State v. Patrick, 164 Ohio St.3d 309 , 2020-Ohio-6803 , 172 N.E.3d 952, ¶ 1-2, 22 (constitutional challenge to sentence could be maintained despite prohibition against appellate review in R.C. 2953.08(D)(3)).2 R.C. 2953.08(D)(1)’s limitation on a defendant’s ability to challenge a jointly recommended sentence on appeal applies to sentences imposed pursuant to plea agreements involving an agreed specific term, plea agreements involving a jointly recommended sentencing range and plea agreements involving pleas to multiple offenses with a jointly recommended aggregate sentencing range.

11

Also cited on this issue (46)

CaseCitedYears
Chase Manhattan Mtge. v. Urquhart, Unpublished Decision (9-6-2005) green
ohioctapp · 2005
2 sentences

2008Corp. , supra. On the other hand, once an appeal is filed, a trial court loses the ability to rule upon a Civ.

2008Corp. , supra. On the other hand, a trial court loses the ability to rule upon a Civ.

62008–2008
Singer v. Dickinson green
ohio · 1992
2 sentences

2024“The net value of the deduction itself, however, does not determine the total tax benefit under either [Singer v. Dickinson, 63 Ohio St.3d 408, 414 , 588 N.E.2d 806 (1992)], or R.C. 3119.82, because while the net value of the ability to claim the exemption may be greater for the party who has the higher income (presuming that the individual with greater income pays tax at a higher rate), the party with the lower income may be eligible for other credits, deductions, or exemptions by virtue of the ability to claim a dependent child.

2024“The net value of the deduction itself, however, does not determine the total tax benefit under either [Singer v. Dickinson, 63 Ohio St.3d 408, 414 , 588 N.E.2d 806 (1992)], or R.C. 3119.82, because while the net value of the ability to claim the exemption may be greater for the party who has the higher income (presuming that the individual with greater income pays tax at a higher rate), the party with the lower income may be eligible for other credits, deductions, or exemptions by virtue of the ability to claim a dependent child.

22012–2024
State v. Obermiller (Slip Opinion) green
ohio · 2016
1 sentence

2024In support of its waiver argument, the State cites cases in which this court and the Ohio Supreme Court have held that a voluntary guilty plea in adult court waives the ability to challenge the ruling on a pretrial suppression motion, State v. Obermiller, 2016-Ohio-1594, ¶ 56 , to claim his or her statutory speedy trial rights were violated, State v. Kelley, 57 Ohio St.3d 127, 130 (1991), or to claim ineffective assistance of counsel, unless the plea was induced by that ineffective assistance, State v. Geraci, 2015-Ohio-2699 , ¶ 14 (8th Dist.).

12024–2024
State ex rel. Scott v. Streetsboro (Slip Opinion) neutral
ohio · 2016
1 sentence

2024Scott v. Streetsboro, 2016-Ohio-3308, ¶ 14 . 18 OHIO FIRST DISTRICT COURT OF APPEALS waived the ability to challenge it now.

12024–2024
In RE ADOPTION OF M.G.B.-E. Et Al. green
ohio · 2018
2 sentences

2022Further, we have limited Pushcar and its progeny to require a probate court to refrain from proceeding with an adoption only when an issue of parentage pending in another court “affect[s] the probate court’s ability to rule on the concurrent adoption petitions.” (Emphasis sic.) In re Adoption of M.G.B.-E., 154 Ohio St.3d 17 , 2018-Ohio-1787 , 110 N.E.3d 1236, ¶ 35 . {¶ 36} The probate court had jurisdiction over H.P.’s adoption proceeding and was authorized to make its determination that K.W.’s consent was not required before K.W. filed anything in the juvenile court.

2022Further, we have limited Pushcar and its progeny to require a probate court to refrain from proceeding with an adoption only when an issue of parentage pending in another court “affect[s] the probate court’s ability to rule on the concurrent adoption petitions.” (Emphasis sic.) In re Adoption of M.G.B.-E., 154 Ohio St.3d 17 , 2018-Ohio-1787 , 110 N.E.3d 1236, ¶ 35 . {¶ 36} The probate court had jurisdiction over H.P.’s adoption proceeding and was authorized to make its determination that K.W.’s consent was not required before K.W. filed anything in the juvenile court.

12022–2022
State v. Ford (Slip Opinion) green
ohio · 2019
1 sentence

2022State v. Ford, 158 Ohio St.3d 139 , 2019-Ohio-4539 , 140 N.E.3d 616 , ¶ 196. conclude that the trial court erred in denying the motion to suppress and the second assignment of error is overruled.

12022–2022
In re Palcisco green
ohioctapp · 2012
1 sentence

2022Trumbull No. 2012-T-0031, 2012-Ohio-6134 (relying on Castle to reject argument that R.C. 3119.86(A) does not grant a domestic relations court whose jurisdiction has terminated pursuant to R.C. 3119.86(B) or (C) the ability to claim ”power anew” on behalf of an “adult-aged child who is disabled”); In re Edgell, 11th Dist.

12022–2022
State ex rel. Romine v. McIntosh (Slip Opinion) green
ohio · 2020
2 sentences

2021Romine v. McIntosh, 162 Ohio St.3d 501 , 2020-Ohio-6826, ¶ 12 .

2021Romine v. McIntosh, 162 Ohio St.3d 501 , 2020-Ohio-6826, ¶ 12 .

12021–2021
State v. Berry green
ohio · 1997
2 sentences

2021These pivotal points along the continuum of a death-penalty prosecution are critical events that could serve in whole or in part to tip the scales of justice toward or away from the ultimate punishment—death. {¶ 201} Therefore, it is understood that R.C. 2945.37(B) dictates that when requested before trial, a competency examination is mandatory and that when a defendant wishes to waive the ability to challenge an imposed death sentence, a 57 SUPREME COURT OF OHIO competency hearing is required, see State v. Berry, 80 Ohio St.3d 371, 375 , 686 N.E.2d 1097 (1997).

2021These pivotal points along the continuum of a death-penalty prosecution are critical events that could serve in whole or in part to tip the scales of justice toward or away from the ultimate punishment—death. {¶ 201} Therefore, it is understood that R.C. 2945.37(B) dictates that when requested before trial, a competency examination is mandatory and that when a defendant wishes to waive the ability to challenge an imposed death sentence, a 57 SUPREME COURT OF OHIO competency hearing is required, see State v. Berry, 80 Ohio St.3d 371, 375 , 686 N.E.2d 1097 (1997).

12021–2021
State v. Ropp green
ohioctapp · 2020
1 sentence

2020However, in two apparently little-recognized cases, the Ohio Supreme court has held that a failure to timely file a Crim.R. 29(A) motion during a [Cite as State v. Ropp, 2020-Ohio-824 .] jury trial does not waive an argument on appeal concerning the sufficiency of the evidence.

12020–2020
Montgomery v. Montgomery, H-06-035 (5-25-2007) green
ohioctapp · 2007
1 sentence

2019Huron No. H-06-035, 2007-Ohio-2539 , ¶ 27- 28 (noting that the ability to claim a dependent on the earned income credit could provide more of a benefit to one parent notwithstanding the other parent’s higher income).

12019–2019
State ex rel. Plain Dealer Publishing Co. v. City of Cleveland neutral
ohio · 2005
2 sentences

2018Plain Dealer Publishing Co. v. Cleveland, 106 Ohio St.3d 70 , 2005-Ohio-3807 , 831 N.E.2d 987 , ¶ 54, we should not foreclose a respondent’s ability to challenge a finding of domestic violence in a CPO when we know that it is probable or certain that that finding will have an effect on future parenting determinations.

2018Plain Dealer Publishing Co. v. Cleveland , 106 Ohio St.3d 70 , 2005-Ohio-3807 , 831 N.E.2d 987 , ¶ 54, we should not foreclose a respondent's ability to challenge a finding of domestic violence in a CPO when we know that it is probable or certain that that finding will have an effect on future parenting determinations.

12018–2018
State v. Webster green
ohioctapp · 2017
1 sentence

2018Cuyahoga No. 104484, 2017-Ohio-932, ¶ 7 , citing State v. Akins-Daniels, 8th Dist.

12018–2018
Hall v. Beals green
scotus · 1969
1 sentence

2017Id. at 1037 ; Conde v. Open Door Marketing, LLC , 223 F.Supp.3d 949 , 960 (N.D.Cal.2017) ("[p]laintiffs are not personally affected by the arbitration agreements at issue because they have not signed agreements that contain similar terms," and "therefore have no interest in the enforceability of the arbitration agreement itself, and lack the ability to challenge the agreements on behalf of individuals who did sign such agreements"); Tan , 2016 WL 4721439 , at *6 (the named plaintiff "has no standing to challenge the applicability or enforceability of the arbitration and class action waiver pro

12017–2017
Conde v. Open Door Marketing, LLC green
cand · 2017
1 sentence

2017Id. at 1037 ; Conde v. Open Door Marketing, LLC , 223 F.Supp.3d 949 , 960 (N.D.Cal.2017) ("[p]laintiffs are not personally affected by the arbitration agreements at issue because they have not signed agreements that contain similar terms," and "therefore have no interest in the enforceability of the arbitration agreement itself, and lack the ability to challenge the agreements on behalf of individuals who did sign such agreements"); Tan , 2016 WL 4721439 , at *6 (the named plaintiff "has no standing to challenge the applicability or enforceability of the arbitration and class action waiver pro

12017–2017
Goldfuss v. Davidson green
ohio · 1997
2 sentences

2017“In appeals of civil cases, the plain error doctrine is not favored and may be applied only in the extremely rare case involving exceptional circumstances where error, to which no objection was made at the trial court, seriously affects the basic fairness, integrity, or public reputation of the judicial process, thereby challenging the legitimacy of the underlying judicial process itself.” Goldfuss v. Davidson, 79 Ohio St.3d 116 , 679 N.E.2d 1099 (1997), syllabus. 4 {¶11} Essentially, we must determine whether the municipal court committed plain error in its determination that there were no er

2017“In appeals of civil cases, the plain error doctrine is not favored and may be applied only in the extremely rare case involving exceptional circumstances where error, to which no objection was made at the trial court, seriously affects the basic fairness, integrity, or public reputation of the judicial process, thereby challenging the legitimacy of the underlying judicial process itself.” Goldfuss v. Davidson, 79 Ohio St.3d 116 , 679 N.E.2d 1099 (1997), syllabus. 4 {¶11} Essentially, we must determine whether the municipal court committed plain error in its determination that there were no er

12017–2017
National Labor Relations Board v. Alternative Entertainment, Inc. green
ca6 · 2017
1 sentence

2017Labor Relations Bd. v. Alternative Entertainment, Inc. , 858 F.3d 393 (6th Cir.2017), does not foreclose the issue of whether Gembarski satisfies the typicality and adequacy requirements for class certification.

12017–2017
State v. Darks, Unpublished Decision (6-22-2006) green
ohioctapp · 2006
12017–2017
Geauga County Bar Ass'n v. Taber green
ohio · 1990
12016–2016
State v. Smorgala green
ohio · 1990
12016–2016
Painter v. Graley green
ohio · 1994
12016–2016
Nemeth v. Nemeth, 2008-G-2830 (9-12-2008) neutral
ohioctapp · 2008
12016–2016
Bank of New York Mellon v. Clancy green
ohioctapp · 2014
12015–2015
Rodgers v. Capots green
ohio · 1993
12014–2014
State v. Pettway neutral
ohioctapp · 2013
12013–2013
Eastley v. Volkman green
ohio · 2012
12012–2012
Hughes v. Cuyahoga County Republican Party Executive Committee green
ohio · 1995
12011–2011
Aetna Insurance v. Kennedy Ex Rel. Bogash green
scotus · 1937
12010–2010
Johnson v. Zerbst green
scotus · 1938
12010–2010
State v. Gilmore, C-070521 (7-11-2008) green
ohioctapp · 2008
12010–2010
State v. Adams green
ohio · 1989
12010–2010
State v. Gardner green
ohio · 2008
12010–2010
State v. Fore green
ohioctapp · 1969
12008–2008
Village of Montpelier v. Greeno green
ohio · 1986
12007–2007
Brott Mardis & Co. v. Camp green
ohioctapp · 2001
12006–2006
State v. Johnson neutral
ohioctapp · 1992
12003–2003
State v. Schoen green
ohio · 1990
12003–2003
Woods v. Telb green
ohio · 2000
12003–2003
Evans v. Medical & Professional Collection Services, Inc. green
indctapp · 2001
12002–2002
State v. Elliott green
ohioctapp · 1993
12001–2001

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.11 (5) OH § Ohio Rev. Code § 2907.02 (4) OH § Ohio Rev. Code § 2921.12 (4) OH § Ohio Rev. Code § 2923.13 (4) OH § Ohio Rev. Code § 2929.14 (4) OH § Ohio Rev. Code § 2941.25 (4) OH § Ohio Rev. Code § 2953.08 (4) OH § Ohio Rev. Code § 2953.21 (4) OH § Ohio Rev. Code § 2151.23 (3) OH § Ohio Rev. Code § 2929.11 (3) OH § Ohio Rev. Code § 2941.145 (3) OH § Ohio Rev. Code § 2953.23 (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 97 (1964–2026) IL 86 (1976–2026) PA 78 (1975–2026) OH 56 (1982–2026) IN 54 (1973–2025) TX 42 (1984–2025) MD 33 (1970–2021) NY 27 (1967–2026) WA 27 (1996–2026) MI 24 (1987–2025) FL 21 (1990–2025) NC 21 (1980–2023) KS 16 (1974–2025) CT 14 (1995–2024) CO 12 (1987–2026) OR 12 (1999–2026) DC 11 (1980–2023) NJ 10 (1993–2023) AZ 10 (1914–2023) IA 8 (2000–2021) LA 8 (1977–2016) TN 8 (2002–2023) NV 8 (2010–2024) DE 8 (1993–2024) MO 7 (1994–2020) AR 7 (2013–2024) WI 7 (1981–2026) NM 7 (1981–2024) UT 6 (1982–2014) ID 6 (2007–2022) ND 5 (2007–2023) MA 5 (2003–2023) ME 5 (1991–2025) SD 5 (1978–2026) KY 5 (1995–2026) AK 5 (1983–2025) SC 4 (2007–2025) MN 4 (2001–2014) MT 4 (1994–2022) VT 4 (2016–2026) NE 4 (1992–2026) RI 3 (1997–2011) OK 3 (1990–2013) HI 3 (2006–2014) MS 3 (1994–2005) VI 3 (2001–2017) AL 3 (1987–2024) WY 2 (2003–2025) GA 2 (2019–2020) VA 2 (2013–2023)

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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