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305 Ohio opinions name it 2 courts 1990–2026 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.
| Case | Followed | Cited |
|---|---|---|
Strickland v. Washingtongreen2 sentences2026When ineffective assistance of counsel is alleged, the petitioner must satisfy the two- prong test of Strickland v. Washington, 466 U.S. 668 (1984), by showing deficient performance and resulting prejudice. {¶29} In evaluating affidavits submitted in support of the petition, a trial court may assess credibility and consider whether the affidavits are internally inconsistent, rely on hearsay, are drafted in similar language, or contradict the record. 2026Shafer further claims that he was prejudiced because he would not have entered a guilty plea but for his attorney’s “relentless pressure” to plead guilty. {¶ 6} We review alleged instances of ineffective assistance of counsel under the two- prong analysis found in Strickland v. Washington, 466 U.S. 668 (1984), which the Ohio Supreme Court adopted in State v. Bradley, 42 Ohio St.3d 136 (1989). | 4 | 272 |
State v. Bradleygreen2 sentences2026Shafer further claims that he was prejudiced because he would not have entered a guilty plea but for his attorney’s “relentless pressure” to plead guilty. {¶ 6} We review alleged instances of ineffective assistance of counsel under the two- prong analysis found in Strickland v. Washington, 466 U.S. 668 (1984), which the Ohio Supreme Court adopted in State v. Bradley, 42 Ohio St.3d 136 (1989). 2026He invokes the familiar two- prong test from Strickland v. Washington, 466 U.S. 668 (1984), and State v. Bradley, 42 Ohio St.3d 136 (1989), which requires a showing of deficient performance and prejudice. 1. | 4 | 104 |
State v. Broomgreen2 sentences2004See Broom, 40 Ohio St.3d at 282 -83 . 2004See Broom , 40 Ohio St.3d at 282 -83 . | 3 | 3 |
State v. Xiegreen2 sentences2019Strickland at 687, 104 S.Ct. 2052 ; Xie at 524, 584 N.E.2d 715 . 1999See Hill v. Lockhart (1985), 474 U.S. 52 , relied upon in State v. Xie (1992), 62 Ohio St.3d 521 , 524 . 2. | 2 | 2 |
State v. Reedgreen2 sentences2014Smith at ¶ 7. {¶4} In addition, the Supreme Court of Ohio, in State v. Spivey, 84 Ohio St.3d 24 , 1998-Ohio-704 , 701 N.E.2d 696 , held that: In State v. Reed (1996), 74 Ohio St.3d 534, 535 , 660 N.E.2d 456, 458 , we held that the two prong analysis found in Strickland v.Washington (1984), 466 U.S. 668 , 104 S.Ct 2052 , 80 L.Ed 674, is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issues he now presents, as well as showing that had he presented those claims on appeal, the 2014Smith at ¶ 7. {¶4} In addition, the Supreme Court of Ohio, in State v. Spivey, 84 Ohio St.3d 24 , 1998-Ohio-704 , 701 N.E.2d 696 , held that: In State v. Reed (1996), 74 Ohio St.3d 534, 535 , 660 N.E.2d 456, 458 , we held that the two prong analysis found in Strickland v.Washington (1984), 466 U.S. 668 , 104 S.Ct 2052 , 80 L.Ed 674, is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issues he now presents, as well as showing that had he presented those claims on appeal, the | 1 | 92 |
State v. Reedgreen2 sentences2011State v. Reed, 74 Ohio St.3d 534 , 1996-Ohio-21 , 660 N.E.2d 456 . {¶ 4} “In State v. Reed [supra, at 458 ] we held that the two prong analysis found in Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 , is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel was deficient for failing to raise the issue he now presents, as well as showing that had he presented those claims on appeal, there was a ‘reasonable probability’ that he would have been successful. 2007"In State v. Reed , 74 Ohio St.3d 534 , 1996-Ohio-21 , 535, 660 N.E.2d 456 , 458 , we held that the two prong analysis found in Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 , is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issue he now presents, as well as showing that had he presented those claims on appeal, there was a `reasonable probability' that he would have been successful. | 1 | 9 |
Hill v. Lockhartgreen2 sentences2024“When a defendant alleges ineffective 15. assistance of counsel arising from the plea process, the defendant must meet the two- prong test set out in Strickland [v. Washington], 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 .” State v. Romero, 156 Ohio St.3d 468 , 2019-Ohio-1839 , 129 N.E.3d 404, ¶ 14 , citing Hill v. Lockhart, 474 U.S. 52, 58 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985) (additional citation omitted.). 2024“When a defendant alleges ineffective 15. assistance of counsel arising from the plea process, the defendant must meet the two- prong test set out in Strickland [v. Washington], 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 .” State v. Romero, 156 Ohio St.3d 468 , 2019-Ohio-1839 , 129 N.E.3d 404, ¶ 14 , citing Hill v. Lockhart, 474 U.S. 52, 58 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985) (additional citation omitted.). | 1 | 2 |
State v. Calhoungreen1 sentence2026Calhoun, 86 Ohio St.3d at 285. | 1 | 1 |
United States v. Orvid v. Garrettgreen1 sentence2014No. 50830, 2009 WL 3191711 (Nev.2009) (“A hearing on a motion to withdraw a guilty plea is a critical stage of litigation, and a defendant therefore has a right to counsel at the hearing.”); Kansas v. Taylor, 266 Kan. 967, 975 , 975 P.2d 1196 (1999); Stephens v. Florida, 141 So.3d 701, 702 (Fla.App.2014); United States v. Sanchez-Barreto, 93 F.3d 17 (1st Cir.1996); Forbes v. United States, 574 F.3d 101 (2d Cir.2009); United States v. Garrett, 90 F.3d 210, 212 (7th Cir.1996). {¶ 16} In general, we review alleged instances of ineffective assistance of trial counsel under the two prong analysis s | 1 | 1 |
Rickardo Stephens v. Stategreen1 sentence2014No. 50830, 2009 WL 3191711 (Nev.2009) (“A hearing on a motion to withdraw a guilty plea is a critical stage of litigation, and a defendant therefore has a right to counsel at the hearing.”); Kansas v. Taylor, 266 Kan. 967, 975 , 975 P.2d 1196 (1999); Stephens v. Florida, 141 So.3d 701, 702 (Fla.App.2014); United States v. Sanchez-Barreto, 93 F.3d 17 (1st Cir.1996); Forbes v. United States, 574 F.3d 101 (2d Cir.2009); United States v. Garrett, 90 F.3d 210, 212 (7th Cir.1996). {¶ 16} In general, we review alleged instances of ineffective assistance of trial counsel under the two prong analysis s | 1 | 1 |
| Collins v. Click Camera & Video, Inc.green | 1 | 1 |
| In re Cunninghamgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Spivey
green
2 sentences2014Smith at ¶ 7. {¶4} In addition, the Supreme Court of Ohio, in State v. Spivey, 84 Ohio St.3d 24 , 1998-Ohio-704 , 701 N.E.2d 696 , held that: In State v. Reed (1996), 74 Ohio St.3d 534, 535 , 660 N.E.2d 456, 458 , we held that the two prong analysis found in Strickland v.Washington (1984), 466 U.S. 668 , 104 S.Ct 2052 , 80 L.Ed 674, is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issues he now presents, as well as showing that had he presented those claims on appeal, the 2014Smith at ¶ 7. {¶4} In addition, the Supreme Court of Ohio, in State v. Spivey, 84 Ohio St.3d 24 , 1998-Ohio-704 , 701 N.E.2d 696 , held that: In State v. Reed (1996), 74 Ohio St.3d 534, 535 , 660 N.E.2d 456, 458 , we held that the two prong analysis found in Strickland v.Washington (1984), 466 U.S. 668 , 104 S.Ct 2052 , 80 L.Ed 674, is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issues he now presents, as well as showing that had he presented those claims on appeal, the | 59 | 1999–2020 |
State v. Spivey
green
2 sentences2014Smith at ¶ 7. {¶4} In addition, the Supreme Court of Ohio, in State v. Spivey, 84 Ohio St.3d 24 , 1998-Ohio-704 , 701 N.E.2d 696 , held: In State v. Reed (1996), 74 Ohio St.3d 534, 535 , 660 N.E.2d 456, 458 , we held that the two prong analysis found in Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed 674, is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issues he now presents, as well as showing that had he presented those claims on appeal, there 2014Smith at ¶ 7. {¶4} In addition, the Supreme Court of Ohio, in State v. Spivey, 84 Ohio St.3d 24 , 1998-Ohio-704 , 701 N.E.2d 696 , held that: In State v. Reed (1996), 74 Ohio St.3d 534, 535 , 660 N.E.2d 456, 458 , we held that the two prong analysis found in Strickland v.Washington (1984), 466 U.S. 668 , 104 S.Ct 2052 , 80 L.Ed 674, is the appropriate standard to assess a defense request for reopening under App.R. 26(B)(5). [Applicant] must prove that his counsel were deficient for failing to raise the issues he now presents, as well as showing that had he presented those claims on appeal, the | 34 | 2002–2014 |
State v. Kalish
red
2 sentences2014Christopher Gee abandoned the two prong analysis set forth in State v. Kalish, 120 Ohio St.3d 23 , 2008-Ohio-4912 , 896 N.E.2d 124 . 2014Christopher Gee abandoned the two prong analysis set forth in State v. Kalish, 120 Ohio St.3d 23 , 2008-Ohio-4912 , 896 N.E.2d 124 . | 4 | 2009–2014 |
State v. Reynolds
green
2 sentences2005State v. Reynolds (1998), 80 Ohio St.3d 670 , 674 . 2003Strickland v. Washington (1984), 466 U.S 668 , 686 ; State v. Reynolds (1998), 80 Ohio St.3d 670 , 674 . | 3 | 2003–2005 |
State v. Thompson
green
2 sentences2003Strickland v. Washington (1984), 466 U.S 668 , 686 ; Thompson , 33 Ohio St.3d at 10 . 2001Strickland v. Washington (1984), 466 U.S. 668 , 686 ; State v. Thompson (1987), 33 Ohio St.3d 1 , 10 . | 3 | 2001–2003 |
State v. Davis (Slip Opinion)
green
2 sentences2026“In order to prevail on an ineffective-assistance-of-counsel claim, a defendant must prove that counsel’s performance was deficient and that the defendant was prejudiced by counsel’s deficient performance.” State v. Davis, 2020-Ohio-309, ¶ 10 , citing Bradley at 141-142 and Strickland at 687 . 2020In light of the Ohio Supreme Court’s recent decision in State v. Davis, Slip Opinion No. 2020-Ohio-309 , --N.E.3d--, on the record of the instant case, we agree. {¶41} To succeed on a claim of ineffectiveness, a defendant must satisfy a two- prong test. | 2 | 2020–2026 |
State v. Hutton
green
2 sentences2004Lowe, 69 Ohio St.3d at 531 , citing State v. Hutton (1990), 53 Ohio St.3d 36 , 40 . {¶ 19} In the instant case, the evidence of Mr. McAdory's prior sexual acts and corresponding convictions satisfy the Supreme Court's two prong test governing other acts evidence. 2003Lowe, 69 Ohio St.3d at 531 , citing State v. Hutton (1990), 53 Ohio St.3d 36 , 40 . {¶ 18} In the instant case, the evidence of Mr. McAdory's prior sexual acts and corresponding convictions satisfy the Supreme Court's two prong test governing other acts evidence. | 2 | 2003–2004 |
State v. Lowe
green
2 sentences2004Lowe, 69 Ohio St.3d at 531 , citing State v. Hutton (1990), 53 Ohio St.3d 36 , 40 . {¶ 19} In the instant case, the evidence of Mr. McAdory's prior sexual acts and corresponding convictions satisfy the Supreme Court's two prong test governing other acts evidence. 2003Lowe, 69 Ohio St.3d at 531 , citing State v. Hutton (1990), 53 Ohio St.3d 36 , 40 . {¶ 18} In the instant case, the evidence of Mr. McAdory's prior sexual acts and corresponding convictions satisfy the Supreme Court's two prong test governing other acts evidence. | 2 | 2003–2004 |
State v. Romero (Slip Opinion)
green
2 sentences2024“When a defendant alleges ineffective 15. assistance of counsel arising from the plea process, the defendant must meet the two- prong test set out in Strickland [v. Washington], 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 .” State v. Romero, 156 Ohio St.3d 468 , 2019-Ohio-1839 , 129 N.E.3d 404, ¶ 14 , citing Hill v. Lockhart, 474 U.S. 52, 58 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985) (additional citation omitted.). 2024“When a defendant alleges ineffective 15. assistance of counsel arising from the plea process, the defendant must meet the two- prong test set out in Strickland [v. Washington], 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 .” State v. Romero, 156 Ohio St.3d 468 , 2019-Ohio-1839 , 129 N.E.3d 404, ¶ 14 , citing Hill v. Lockhart, 474 U.S. 52, 58 , 106 S.Ct. 366 , 88 L.Ed.2d 203 (1985) (additional citation omitted.). | 1 | 2024–2024 |
State v. Jenkins
neutral
1 sentence2022Montgomery No. 27173, 2017-Ohio-1073, ¶ 10 . {¶ 15} Boyle has failed to allege or assert any facts that would satisfy the two- prong test set forth in R.C. 2953.23(A)(1). | 1 | 2022–2022 |
Blakemore v. Blakemore
green
2 sentences2022Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983). {¶ 12} Boyle has failed to allege or assert any facts that would satisfy the two- prong test set forth in R.C. 2953.23(A)(1). 2022Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983). {¶ 12} Boyle has failed to allege or assert any facts that would satisfy the two- prong test set forth in R.C. 2953.23(A)(1). | 1 | 2022–2022 |
State v. Dalton
green
2 sentences2020No. 16-CA-85, 2017-Ohio-4058 , 91 N.E.3d 326, ¶ 18 , citing State v. Dalton, 153 Ohio App.3d 286, 292 , 2003-Ohio-3813 , 793 N.E.2d 509 (10th Dist.). {¶25} To succeed on a claim of ineffectiveness, a defendant must satisfy a two- prong test. 2020No. 16-CA-85, 2017-Ohio-4058 , 91 N.E.3d 326, ¶ 18 , citing State v. Dalton, 153 Ohio App.3d 286, 292 , 2003-Ohio-3813 , 793 N.E.2d 509 (10th Dist.). {¶25} To succeed on a claim of ineffectiveness, a defendant must satisfy a two- prong test. | 1 | 2020–2020 |
State v. Adames
green
2 sentences2020No. 16-CA-85, 2017-Ohio-4058 , 91 N.E.3d 326, ¶ 18 , citing State v. Dalton, 153 Ohio App.3d 286, 292 , 2003-Ohio-3813 , 793 N.E.2d 509 (10th Dist.). {¶25} To succeed on a claim of ineffectiveness, a defendant must satisfy a two- prong test. 2020No. 16-CA-85, 2017-Ohio-4058 , 91 N.E.3d 326, ¶ 18 , citing State v. Dalton, 153 Ohio App.3d 286, 292 , 2003-Ohio-3813 , 793 N.E.2d 509 (10th Dist.). {¶25} To succeed on a claim of ineffectiveness, a defendant must satisfy a two- prong test. | 1 | 2020–2020 |
State v. Jackson
green
1 sentence2020To show prejudice, defendant must show a reasonable probability that, but for his counsel's errors, the result of the proceeding would have been different." State v. Jackson, 107 Ohio St.3d 53 , 2005-Ohio-5981 , ¶ 133, citing Strickland. | 1 | 2020–2020 |
State v. Mitchell, 21957 (2-8-2008)
green
1 sentence2016Montgomery No. 21957, 2008-Ohio-493 , we noted that: We review the alleged instances of ineffective assistance of trial counsel under the two prong analysis set forth in Strickland v. Washington (1984), 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 , and adopted by the Supreme Court of Ohio in State v. Bradley (1989), 42 Ohio St.3d 136 , 538 N.E.2d 373 . | 1 | 2016–2016 |
Zimmie v. Calfee, Halter & Griswold
green
2 sentences2016As reflected within Zimmie v. Calfee, Halter and Griswold, 43 Ohio St.3d 54, 58 , 538 N.E.2d 398 (1989), the Supreme Court of Ohio has created a two prong test to evaluate when the accrual date for a legal malpractice action starts. 2016As reflected within Zimmie v. Calfee, Halter and Griswold, 43 Ohio St.3d 54, 58 , 538 N.E.2d 398 (1989), the Supreme Court of Ohio has created a two prong test to evaluate when the accrual date for a legal malpractice action starts. | 1 | 2016–2016 |
Forbes v. United States
green
1 sentence2014No. 50830, 2009 WL 3191711 (Nev.2009) (“A hearing on a motion to withdraw a guilty plea is a critical stage of litigation, and a defendant therefore has a right to counsel at the hearing.”); Kansas v. Taylor, 266 Kan. 967, 975 , 975 P.2d 1196 (1999); Stephens v. Florida, 141 So.3d 701, 702 (Fla.App.2014); United States v. Sanchez-Barreto, 93 F.3d 17 (1st Cir.1996); Forbes v. United States, 574 F.3d 101 (2d Cir.2009); United States v. Garrett, 90 F.3d 210, 212 (7th Cir.1996). {¶ 16} In general, we review alleged instances of ineffective assistance of trial counsel under the two prong analysis s | 1 | 2014–2014 |
| Neil v. Biggers green | 1 | 2014–2014 |
| State v. Taylor green | 1 | 2014–2014 |
State v. Waddy
yellow
2 sentences2014State v. Waddy, 63 Ohio St.3d 424, 438 , 588 N.E.2d 819 (1992), citing Neil v. Biggers, 409 U.S. 188 , 93 S.Ct. 375 , 34 L.Ed.2d 401 (1972). -17- An identification is unreliable if there is a very substantial likelihood of irreparable misidentification under the totality of the circumstances. 2014State v. Waddy, 63 Ohio St.3d 424, 438 , 588 N.E.2d 819 (1992), citing Neil v. Biggers, 409 U.S. 188 , 93 S.Ct. 375 , 34 L.Ed.2d 401 (1972). -17- An identification is unreliable if there is a very substantial likelihood of irreparable misidentification under the totality of the circumstances. | 1 | 2014–2014 |
Oregon v. Ice
green
1 sentence2014Id., ¶12. {¶75} In Oregon v. Ice, 555 U.S. 160 (2009), the United States Supreme Court held that it was constitutionally permissible to require judicial fact-finding before imposing consecutive sentences. | 1 | 2014–2014 |
United States v. Sanchez Barreto
green
1 sentence2014No. 50830, 2009 WL 3191711 (Nev.2009) (“A hearing on a motion to withdraw a guilty plea is a critical stage of litigation, and a defendant therefore has a right to counsel at the hearing.”); Kansas v. Taylor, 266 Kan. 967, 975 , 975 P.2d 1196 (1999); Stephens v. Florida, 141 So.3d 701, 702 (Fla.App.2014); United States v. Sanchez-Barreto, 93 F.3d 17 (1st Cir.1996); Forbes v. United States, 574 F.3d 101 (2d Cir.2009); United States v. Garrett, 90 F.3d 210, 212 (7th Cir.1996). {¶ 16} In general, we review alleged instances of ineffective assistance of trial counsel under the two prong analysis s | 1 | 2014–2014 |
| In Re Fell, Unpublished Decision (10-31-2005) green | 1 | 2013–2013 |
| State v. Barnett green | 1 | 2013–2013 |
| Contreras v. Ferro Corp. green | 1 | 2013–2013 |
| In Re S.A., 07-Ca-110 (5-5-2008) green | 1 | 2012–2012 |
| State v. Mathews green | 1 | 2009–2009 |
| In Re Shrider, Unpublished Decision (6-5-2006) green | 1 | 2008–2008 |
| State v. Madrigal green | 1 | 2008–2008 |
| State v. Rojas green | 1 | 2008–2008 |
| State v. Madrigal green | 1 | 2008–2008 |
| State v. Conway green | 1 | 2008–2008 |
| Cash v. City of Cincinnati green | 1 | 2005–2005 |
| State v. Smith green | 1 | 2003–2003 |
| State v. Lott green | 1 | 2003–2003 |
| Nelson v. Ford Motor Co. green | 1 | 2002–2002 |
| Dorsey v. Contemporary Obstetrics & Gynecology, Inc. green | 1 | 2002–2002 |
| Feterle v. Huettner green | 1 | 2002–2002 |
| Insurance Co. of North America v. Automatic Sprinkler Corp. of America green | 1 | 2002–2002 |
| Pesek v. University Neurologists Ass'n green | 1 | 2002–2002 |
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.
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.