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7 Ohio opinions name it 2 courts 2012–2026 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.
| Case | Followed | Cited |
|---|---|---|
State v. Scottgreen2 sentences2026The rule provides that a witness may use a writing to refresh memory for the purpose of testifying “if the court in its discretion determines it is necessary in the interests of justice.” “Under the doctrine of present recollection refreshed, ‘the witness looks at the memorandum to refresh his memory of the events, but then proceeds to testify upon the basis of his present independent knowledge.’ ” State v. Ford, 2019-Ohio-4539, ¶ 230 , quoting State v. Scott, 31 Ohio St.2d 1, 5-6 (1972). 2025The adverse party is also entitled to inspect it, to cross-examine the witness thereon, and to introduce in evidence those portions which relate to the testimony of the witness. -12- {¶ 30} “Under the doctrine of present recollection refreshed, ‘the witness looks at the memorandum to refresh his memory of the events, but then proceeds to testify upon the basis of his present independent knowledge.’” State v. Ford, 2019-Ohio-4539, ¶ 230 , quoting State v. Scott, 31 Ohio St.2d 1, 5-6 (1972). | 2 | 7 |
City of Dayton v. Combsgreen1 sentence2025Before using a writing to refresh the recollection of a witness, “it must be established that the witness lacks a present recollection of the information or events described in the writing.” Dayton v. Combs, 94 Ohio App.3d 291, 297 (2d Dist. 1993). | 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. Powell
green
2 sentences2020Id., citing State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 57, citing State v. Scott, 31 Ohio St.2d 1, 5-6 , 285 N.E.2d 344 (1972). 2020Id., citing State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 57, citing State v. Scott, 31 Ohio St.2d 1, 5-6 , 285 N.E.2d 344 (1972). | 3 | 2014–2020 |
State v. Ford (Slip Opinion)
green
2 sentences2026The rule provides that a witness may use a writing to refresh memory for the purpose of testifying “if the court in its discretion determines it is necessary in the interests of justice.” “Under the doctrine of present recollection refreshed, ‘the witness looks at the memorandum to refresh his memory of the events, but then proceeds to testify upon the basis of his present independent knowledge.’ ” State v. Ford, 2019-Ohio-4539, ¶ 230 , quoting State v. Scott, 31 Ohio St.2d 1, 5-6 (1972). 2025The adverse party is also entitled to inspect it, to cross-examine the witness thereon, and to introduce in evidence those portions which relate to the testimony of the witness. -12- {¶ 30} “Under the doctrine of present recollection refreshed, ‘the witness looks at the memorandum to refresh his memory of the events, but then proceeds to testify upon the basis of his present independent knowledge.’” State v. Ford, 2019-Ohio-4539, ¶ 230 , quoting State v. Scott, 31 Ohio St.2d 1, 5-6 (1972). | 2 | 2025–2026 |
State v. Webb
neutral
1 sentence2020Id., citing State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 57, citing State v. Scott, 31 Ohio St.2d 1, 5-6 , 285 N.E.2d 344 (1972). | 1 | 2020–2020 |
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.