Matthews motion (Ohio) · Go Syfert
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Matthews motion in Ohio

7 Ohio opinions name it 1 courts 2005–2025 2 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
State v. Lawson (Slip Opinion)green
ohio · 2021 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See State v. Lawson, 165 Ohio St.3d 445 , 2021-Ohio-3566 , 179 N.E.3d 1216, ¶ 77-78 , citing State v. Ballard, 66 Ohio St.2d 473 , 423 N.E.2d 115 (1981) and Crim.R. 11(C)(2)(c). {¶ 21} In this case, the trial court did not reach the merits of Matthews’ claim of ineffective assistance of counsel, finding Matthews’ challenge was based on matters that could have been raised in a direct appeal.

2024See State v. Lawson, 165 Ohio St.3d 445 , 2021-Ohio-3566 , 179 N.E.3d 1216, ¶ 77-78 , citing State v. Ballard, 66 Ohio St.2d 473 , 423 N.E.2d 115 (1981) and Crim.R. 11(C)(2)(c). {¶ 21} In this case, the trial court did not reach the merits of Matthews’ claim of ineffective assistance of counsel, finding Matthews’ challenge was based on matters that could have been raised in a direct appeal.

11
State v. Ballardgreen
ohio · 1981 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See State v. Lawson, 165 Ohio St.3d 445 , 2021-Ohio-3566 , 179 N.E.3d 1216, ¶ 77-78 , citing State v. Ballard, 66 Ohio St.2d 473 , 423 N.E.2d 115 (1981) and Crim.R. 11(C)(2)(c). {¶ 21} In this case, the trial court did not reach the merits of Matthews’ claim of ineffective assistance of counsel, finding Matthews’ challenge was based on matters that could have been raised in a direct appeal.

2024See State v. Lawson, 165 Ohio St.3d 445 , 2021-Ohio-3566 , 179 N.E.3d 1216, ¶ 77-78 , citing State v. Ballard, 66 Ohio St.2d 473 , 423 N.E.2d 115 (1981) and Crim.R. 11(C)(2)(c). {¶ 21} In this case, the trial court did not reach the merits of Matthews’ claim of ineffective assistance of counsel, finding Matthews’ challenge was based on matters that could have been raised in a direct appeal.

11
State v. Spatesgreen
ohio · 1992 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See, e.g., State v. Spates, 64 Ohio St.3d 269, 272 , 595 N.E.2d 351 (1992) (despite the consequences of a guilty plea, a defendant may challenge the effectiveness of counsel relative to the “voluntary and intelligent character of the guilty plea” in a direct appeal). {¶ 23} Matthews’ challenge regarding ineffective assistance of counsel concerns the failure of counsel to challenge admissibility of the evidence, arguing an improper search using a GPS device.

2024See, e.g., State v. Spates, 64 Ohio St.3d 269, 272 , 595 N.E.2d 351 (1992) (despite the consequences of a guilty plea, a defendant may challenge the effectiveness of counsel relative to the “voluntary and intelligent character of the guilty plea” in a direct appeal). {¶ 23} Matthews’ challenge regarding ineffective assistance of counsel concerns the failure of counsel to challenge admissibility of the evidence, arguing an improper search using a GPS device.

11
Doyle v. Ohio Bureau of Motor Vehiclesgreen
ohio · 1990 · cited in 1 Ohio opinions naming this issue, 2016–2016
1 sentence

2016Doyle v. Ohio Bur. of Motor Vehicles, 51 Ohio St.3d 46, 51-52 (1990) (applying Matthews analysis to administrative context in Ohio); Gross v. State Med.

11
State v. Griffingreen
ohioctapp · 2001 · cited in 1 Ohio opinions naming this issue, 2012–2012
1 sentence

2012No. 1–10–10, 2010–Ohio–4819, ¶ 21, citing State v. Griffin, 141 Ohio App.3d 551, 554 (2001). {¶32} In the instant case, the trial court addressed each of these factors in its decision to overrule Matthews’ motion to withdraw his guilty pleas.

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 (3)

CaseCitedYears
Nolan v. Nolan green
ohio · 1984
2 sentences

2005The state’s argument perhaps is overstated, but is persuasive. {¶ 21} The Ohio Supreme Court explained the doctrine of the law of the case in Nolan v. Nolan (1984), 11 Ohio St.3d 1 , 11 OBR 1, 462 N.E.2d 410 , to be a “rule of practice rather than a binding rule of substantive law,” which “functions to compel trial courts to follow the mandates of reviewing courts.” Under this doctrine, “an inferior court has no discretion to disregard” the superior court’s mandate.

2005The state’s argument perhaps is overstated, but is persuasive. {¶ 21} The Ohio Supreme Court explained the doctrine of the law of the case in Nolan v. Nolan (1984), 11 Ohio St.3d 1 , 11 OBR 1, 462 N.E.2d 410 , to be a “rule of practice rather than a binding rule of substantive law,” which “functions to compel trial courts to follow the mandates of reviewing courts.” Under this doctrine, “an inferior court has no discretion to disregard” the superior court’s mandate.

22005–2005
State v. Vasquez green
ohioctapp · 2024
1 sentence

2025I write separately to reiterate the concerns I expressed in State v. Vasquez, 2024-Ohio-2947 (6th Dist.) (Mayle, J., concurring).

12025–2025
Knapp v. Edwards Laboratories green
ohio · 1980
2 sentences

2009Matthews entered a plea of no contest, and the trial court sentenced him to five years of community control sanctions. {¶ 2} Matthews asserts one assignment of error as follows: {¶ 3} "THE TRIAL COURT ERRED TO THE PREJUDICE OF APPELLANT BY OVERRULING HIS MOTION TO SUPPRESS EVIDENCE." {¶ 4} In its decision overruling Matthews' motion to suppress, the trial court adopted "the findings of fact and conclusions of law set forth on the record at the conclusion of the hearing." Attached to Matthews' brief, as Appendix A, is "Attorney Partial Transcription of Videotaped Motion to Suppress Hearing Janu

2009Matthews entered a plea of no contest, and the trial court sentenced him to five years of community control sanctions. {¶ 2} Matthews asserts one assignment of error as follows: {¶ 3} "THE TRIAL COURT ERRED TO THE PREJUDICE OF APPELLANT BY OVERRULING HIS MOTION TO SUPPRESS EVIDENCE." {¶ 4} In its decision overruling Matthews' motion to suppress, the trial court adopted "the findings of fact and conclusions of law set forth on the record at the conclusion of the hearing." Attached to Matthews' brief, as Appendix A, is "Attorney Partial Transcription of Videotaped Motion to Suppress Hearing Janu

12009–2009

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2925.03 (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

TX 16 (1950–2023) MD 9 (1970–2022) OH 7 (2005–2025) WA 6 (2006–2024) NJ 5 (1988–2017) LA 4 (1995–2007) MI 4 (2018–2025) GA 4 (2002–2023) UT 4 (2007–2026) TN 3 (1999–2003) PA 3 (1977–2018) AR 3 (1988–2016) OK 2 (2002–2014) NY 2 (2001–2023) NM 2 (2000–2022) DE 2 (2018–2023) CA 2 (1992–2025)

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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