issue only for plain error (Ohio) · Go Syfert
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issue only for plain error in Ohio

7 Ohio opinions name it 1 courts 2001–2025 3 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 (6)

CaseFollowedCited
State v. Wilson, 22581 (2-6-2009)green
ohioctapp · 2009 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025As Barber moved for acquittal during trial based on the State’s alleged failure to prove when the sexual abuse occurred, we review this issue only for plain error. {¶ 45} “A sufficiency of the evidence argument disputes whether the State has presented adequate evidence on each element of the offense to allow the case to go to the jury or sustain the verdict as a matter of law.” State v. Wilson, 2009-Ohio-525, ¶ 10 (2d Dist.), citing State v. Thompkins, 78 Ohio St.3d 380 (1997).

11
State v. Vanculingreen
ohioctapp · 2012 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025State v. Vanculin, 2012-Ohio-292, ¶15 (2d Dist.).

11
State v. Keenangreen
ohio · 1993 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024State v. Keenan, 66 Ohio St.3d 402, 405 (1993).

11
Henderson v. United Statesgreen
scotus · 2013 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019For an error to be “plain” or “obvious,” the error must be plain “under current law” “at the time of appellate consideration.” Johnson v. United States, 520 U.S. 461, 467, 468 , 117 S.Ct. 1544 , 137 L.Ed.2d 718 (1997); accord Henderson v. United States, 568 U.S. 266, 279 , 133 S.Ct. 1121 , 185 L.Ed.2d 85 (2013); Barnes, 94 Ohio St.3d at 27 , 759 N.E.2d 1240 , citing United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 (1993) (noting that for error to be plain, it must be obvious error under current law); State v. G.C., 10th Dist.

2019For an error to be “plain” or “obvious,” the error must be plain “under current law” “at the time of appellate consideration.” Johnson v. United States, 520 U.S. 461, 467, 468 , 117 S.Ct. 1544 , 137 L.Ed.2d 718 (1997); accord Henderson v. United States, 568 U.S. 266, 279 , 133 S.Ct. 1121 , 185 L.Ed.2d 85 (2013); Barnes, 94 Ohio St.3d at 27 , 759 N.E.2d 1240 , citing United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 (1993) (noting that for error to be plain, it must be obvious error under current law); State v. G.C., 10th Dist.

11
Johnson v. United Statesgreen
scotus · 1997 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019For an error to be “plain” or “obvious,” the error must be plain “under current law” “at the time of appellate consideration.” Johnson v. United States, 520 U.S. 461, 467, 468 , 117 S.Ct. 1544 , 137 L.Ed.2d 718 (1997); accord Henderson v. United States, 568 U.S. 266, 279 , 133 S.Ct. 1121 , 185 L.Ed.2d 85 (2013); Barnes, 94 Ohio St.3d at 27 , 759 N.E.2d 1240 , citing United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 (1993) (noting that for error to be plain, it must be obvious error under current law); State v. G.C., 10th Dist.

2019For an error to be “plain” or “obvious,” the error must be plain “under current law” “at the time of appellate consideration.” Johnson v. United States, 520 U.S. 461, 467, 468 , 117 S.Ct. 1544 , 137 L.Ed.2d 718 (1997); accord Henderson v. United States, 568 U.S. 266, 279 , 133 S.Ct. 1121 , 185 L.Ed.2d 85 (2013); Barnes, 94 Ohio St.3d at 27 , 759 N.E.2d 1240 , citing United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 (1993) (noting that for error to be plain, it must be obvious error under current law); State v. G.C., 10th Dist.

11
State v. Thomas (Slip Opinion)green
ohio · 2017 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019Consequently, we may review this issue only for plain error. {¶ 67} Crim.R. 52(B) provides that “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.” Crim.R. 52(B) thus permits a court to recognize plain error if the party claiming error establishes (1) that “‘an error, i.e., a deviation from a legal rule’” occurred, (2) that the error is a plain or “‘an “obvious” ADAMS, 17CA1056 27 defect in the trial proceedings,’” and (3) that this obvious error affected substantial rights, i.e., the error “‘must have affected t

2019Consequently, we may review this issue only for plain error. {¶ 67} Crim.R. 52(B) provides that “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.” Crim.R. 52(B) thus permits a court to recognize plain error if the party claiming error establishes (1) that “‘an error, i.e., a deviation from a legal rule’” occurred, (2) that the error is a plain or “‘an “obvious” ADAMS, 17CA1056 27 defect in the trial proceedings,’” and (3) that this obvious error affected substantial rights, i.e., the error “‘must have affected t

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 (7)

CaseCitedYears
State v. Thompkins red
ohio · 1997
1 sentence

2025As Barber moved for acquittal during trial based on the State’s alleged failure to prove when the sexual abuse occurred, we review this issue only for plain error. {¶ 45} “A sufficiency of the evidence argument disputes whether the State has presented adequate evidence on each element of the offense to allow the case to go to the jury or sustain the verdict as a matter of law.” State v. Wilson, 2009-Ohio-525, ¶ 10 (2d Dist.), citing State v. Thompkins, 78 Ohio St.3d 380 (1997).

12025–2025
United States v. Olano red
scotus · 1993
2 sentences

2019For an error to be “plain” or “obvious,” the error must be plain “under current law” “at the time of appellate consideration.” Johnson v. United States, 520 U.S. 461, 467, 468 , 117 S.Ct. 1544 , 137 L.Ed.2d 718 (1997); accord Henderson v. United States, 568 U.S. 266, 279 , 133 S.Ct. 1121 , 185 L.Ed.2d 85 (2013); Barnes, 94 Ohio St.3d at 27 , 759 N.E.2d 1240 , citing United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 (1993) (noting that for error to be plain, it must be obvious error under current law); State v. G.C., 10th Dist.

2019For an error to be “plain” or “obvious,” the error must be plain “under current law” “at the time of appellate consideration.” Johnson v. United States, 520 U.S. 461, 467, 468 , 117 S.Ct. 1544 , 137 L.Ed.2d 718 (1997); accord Henderson v. United States, 568 U.S. 266, 279 , 133 S.Ct. 1121 , 185 L.Ed.2d 85 (2013); Barnes, 94 Ohio St.3d at 27 , 759 N.E.2d 1240 , citing United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770 , 123 L.Ed.2d 508 (1993) (noting that for error to be plain, it must be obvious error under current law); State v. G.C., 10th Dist.

12019–2019
State v. Barnes green
ohio · 2002
2 sentences

2019Consequently, we may review this issue only for plain error. {¶ 67} Crim.R. 52(B) provides that “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.” Crim.R. 52(B) thus permits a court to recognize plain error if the party claiming error establishes (1) that “‘an error, i.e., a deviation from a legal rule’” occurred, (2) that the error is a plain or “‘an “obvious” ADAMS, 17CA1056 27 defect in the trial proceedings,’” and (3) that this obvious error affected substantial rights, i.e., the error “‘must have affected t

2019Consequently, we may review this issue only for plain error. {¶ 67} Crim.R. 52(B) provides that “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.” Crim.R. 52(B) thus permits a court to recognize plain error if the party claiming error establishes (1) that “‘an error, i.e., a deviation from a legal rule’” occurred, (2) that the error is a plain or “‘an “obvious” ADAMS, 17CA1056 27 defect in the trial proceedings,’” and (3) that this obvious error affected substantial rights, i.e., the error “‘must have affected t

12019–2019
State v. Rogers green
ohio · 2015
2 sentences

2019Consequently, we may review this issue only for plain error. {¶ 67} Crim.R. 52(B) provides that “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.” Crim.R. 52(B) thus permits a court to recognize plain error if the party claiming error establishes (1) that “‘an error, i.e., a deviation from a legal rule’” occurred, (2) that the error is a plain or “‘an “obvious” ADAMS, 17CA1056 27 defect in the trial proceedings,’” and (3) that this obvious error affected substantial rights, i.e., the error “‘must have affected t

2019Consequently, we may review this issue only for plain error. {¶ 67} Crim.R. 52(B) provides that “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the court.” Crim.R. 52(B) thus permits a court to recognize plain error if the party claiming error establishes (1) that “‘an error, i.e., a deviation from a legal rule’” occurred, (2) that the error is a plain or “‘an “obvious” ADAMS, 17CA1056 27 defect in the trial proceedings,’” and (3) that this obvious error affected substantial rights, i.e., the error “‘must have affected t

12019–2019
State v. Quarterman (Slip Opinion) green
ohio · 2014
2 sentences

2016Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, at ¶ 15-16 .

2016Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, at ¶ 15-16 .

12016–2016
In Re Williams green
ohioctapp · 1997
2 sentences

2011Crim.R. 52(B); In re Williams (1997), 116 Ohio App.3d 237, 241 , 687 N.E.2d 507 .

2011Crim.R. 52(B); In re Williams (1997), 116 Ohio App.3d 237, 241 , 687 N.E.2d 507 .

12011–2011
State v. Morgan green
ohioctapp · 1986
1 sentence

2001Id.

12001–2001

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2901.05 (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 7 (2001–2025) IL 7 (1997–2021) UT 6 (2016–2026) AK 6 (1992–2025) MI 4 (2015–2023) GA 3 (2017–2023) NC 3 (2007–2014) VI 2 (2009–2015) DC 2 (2011–2022) NE 2 (2015–2015) TN 2 (2016–2025) AL 2 (1995–2015) WI 2 (2019–2019)

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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