Boyle test (Ohio) · Go Syfert
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Boyle test in Ohio

6 Ohio opinions name it 1 courts 2019–2025 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 (6)

CaseFollowedCited
Boyle v. United Statesgreen
scotus · 2009 · cited in 2 Ohio opinions naming this issue, 2020–2020
2 sentences

2020Under the Boyle test, “an association-in-fact enterprise must have at least three structural features: a purpose, relationships among those associated with the enterprise, and longevity sufficient to permit these associates to pursue the enterprise’s purpose.” Boyle at 946, 129 S.Ct. 2237 .

2020Under the Boyle test, “an association-in-fact enterprise must have at least three structural features: a purpose, relationships among those associated with the enterprise, and longevity sufficient to permit these associates to pursue the enterprise’s purpose.” Boyle at 946, 129 S.Ct. 2237 .

22
State v. Kozicgreen
ohioctapp · 2014 · cited in 2 Ohio opinions naming this issue, 2019–2019
2 sentences

2019No. 11 MA 160, 2014-Ohio-3788, ¶ 64 ("the No. 18AP-51 9 burglaries occurred over the span of months," indicating sufficient longevity under the Boyle test). {¶ 24} Here, all of the predicate offenses occurred on the same day in the same location.

2019No. 11 MA 160, 2014-Ohio-3788, ¶ 64 ("the No. 18AP-51 9 burglaries occurred over the span of months," indicating sufficient longevity under the Boyle test). {¶ 24} Here, all of the predicate offenses occurred on the same day in the same location.

22
State v. Boltongreen
· 2017 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025State v. Bolton, 2017-Ohio-8903, ¶ 13 (2d Dist.). {¶ 20} According to the brief, Boyle’s argument is that he cannot be considered a vexatious litigator because we reversed and remanded one of his cases for the trial court to consider the merits.

11
State v. Boylegreen
· 2023 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025State v. Boyle, 2023-Ohio-3390, ¶ 5 (2d Dist.).

11
Ohio Valley Radiology Associates, Inc. v. Ohio Valley Hospital Ass'ngreen
ohio · 1986 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Assn., 28 Ohio St.3d 118, 121 (1986).

11
State v. Wertmangreen
ohioctapp · 2019 · cited in 1 Ohio opinions naming this issue, 2020–2020
2 sentences

2020Franklin No. 18A P-51, 2019-Ohio-007, ¶ 21 .

2020Franklin No. 18A P-51, 2019-Ohio-007, ¶ 21 .

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 (4)

CaseCitedYears
Anders v. California green
scotus · 1967
1 sentence

2025After conducting a review under Anders v. California, 386 U.S. 738 (1967), we found no arguable merit in Boyle’s claim that the trial court erred in imposing consecutive sentences.

12025–2025
State v. Reynolds green
ohio · 1997
2 sentences

2022Upon review, we find the trial court did not err in construing Boyle’s motion as a petition for post-conviction relief and, thereafter, denying it. {¶ 8} It is well-established that “[c]ourts may recast irregular motions into whatever category necessary to identify and establish the criteria by which the motion should be judged.” State v. Schlee, 117 Ohio St.3d 153 , 2008-Ohio-545 , 882 N.E.2d 431 , ¶ 12. “[W]here a criminal defendant, subsequent to his or her direct appeal, files a motion seeking vacation or correction of his or her sentence on the basis that his or her constitutional rights

2022Upon review, we find the trial court did not err in construing Boyle’s motion as a petition for post-conviction relief and, thereafter, denying it. {¶ 8} It is well-established that “[c]ourts may recast irregular motions into whatever category necessary to identify and establish the criteria by which the motion should be judged.” State v. Schlee, 117 Ohio St.3d 153 , 2008-Ohio-545 , 882 N.E.2d 431 , ¶ 12. “[W]here a criminal defendant, subsequent to his or her direct appeal, files a motion seeking vacation or correction of his or her sentence on the basis that his or her constitutional rights

12022–2022
State v. Steffen green
ohio · 1994
2 sentences

2022At the end, he asked that the trial court review the specifically identified records so that the court could see that he did not receive “a fair trial if one was to be had, a fair plea agreement, a fair direct appeal, a fair delayed appeal, post- conviction, state habea[s], or any other remedy that would be required[.]” While we -6- agree with the trial court that Boyle’s motion was difficult to adequately categorize, we do not think it was unreasonable for the trial court to have construed his motion as an untimely petition for post-conviction relief. {¶ 9} “A post[-]conviction proceeding is

2022At the end, he asked that the trial court review the specifically identified records so that the court could see that he did not receive “a fair trial if one was to be had, a fair plea agreement, a fair direct appeal, a fair delayed appeal, post- conviction, state habea[s], or any other remedy that would be required[.]” While we -6- agree with the trial court that Boyle’s motion was difficult to adequately categorize, we do not think it was unreasonable for the trial court to have construed his motion as an untimely petition for post-conviction relief. {¶ 9} “A post[-]conviction proceeding is

12022–2022
State v. Schlee green
ohio · 2008
1 sentence

2022Upon review, we find the trial court did not err in construing Boyle’s motion as a petition for post-conviction relief and, thereafter, denying it. {¶ 8} It is well-established that “[c]ourts may recast irregular motions into whatever category necessary to identify and establish the criteria by which the motion should be judged.” State v. Schlee, 117 Ohio St.3d 153 , 2008-Ohio-545 , 882 N.E.2d 431 , ¶ 12. “[W]here a criminal defendant, subsequent to his or her direct appeal, files a motion seeking vacation or correction of his or her sentence on the basis that his or her constitutional rights

12022–2022

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2923.31 (4) OH § Ohio Rev. Code § 2923.32 (4) OH § Ohio Rev. Code § 2929.14 (4) OH § Ohio Rev. Code § 2923.03 (3) OH § Ohio Rev. Code § 2925.03 (3) OH § Ohio Rev. Code § 2941.141 (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

MI 8 (1986–2022) OH 6 (2019–2025) TX 5 (1996–2022) PA 4 (1998–2009) CA 4 (2008–2023) WI 4 (1959–1998) NJ 3 (1995–2004) LA 3 (2020–2025) AR 2 (2005–2025)

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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