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

6 Ohio opinions name it 1 courts 2007–2026 4 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 (9)

CaseFollowedCited
State v. Browngreen
ohioctapp · 2006 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See State v. Brown, 2006-Ohio-3266, ¶ 13 (10th Dist.) (“even if the doctrine of res judicata did not bar all of appellant's claims, his own self-serving declarations of coercion would not be enough to show manifest injustice . . .

11
State v. Harrisgreen
ohioctapp · 2024 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See also State v. Harris, 2024-Ohio-2993, ¶ 25 (5th Dist.) (“The affidavit and the search warrant, which Harris claims that his trial attorney was unaware, were issued in 2017.

11
State v. Morrisgreen
ohioctapp · 2026 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026And to avoid the application of claim preclusion to a second motion, a defendant must point to evidence that was not “in existence and available for use at the time of trial.” Spencer at ¶ 20 , quoting Kenney at ¶ 45 . {¶25} All of the discovery materials that Sanchez claims he obtained in 2024 were in existence before he entered his guilty pleas, and Sanchez’s claim that he was unaware of some of those items in 2016 “does not transform [them] into newly discovered evidence.” State v. Morris, 2026-Ohio-37, ¶ 14 (8th Dist.) (“Morris's claim that he was unaware of Exhibit B, a 2014 Lakewood poli

11
State v. Robinsongreen
ohioctapp · 2013 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v. Ramirez, 2019-Ohio-3050, ¶ 32 (12th Dist.) (appellant waiting nearly seven years before filing his motion to withdraw militated against granting appellant's motion); State v. Daniels, 2019-Ohio-2274, ¶ 22 (12th Dist.) ("appellant waited nearly six years after his conviction to move to withdraw his plea which weighs against granting the motion"); State v. Robinson, 2013-Ohio-5672, ¶ 19 (12th Dist.) (appellant waiting four years after his conviction to move to withdraw his plea "clearly militates against" granting appellant's motion to withdraw). {¶ 9} This is only compounded

11
State v. Hoppergreen
ohioctapp · 2013 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v. Ramirez, 2019-Ohio-3050, ¶ 32 (12th Dist.) (appellant waiting nearly seven years before filing his motion to withdraw militated against granting appellant's motion); State v. Daniels, 2019-Ohio-2274, ¶ 22 (12th Dist.) ("appellant waited nearly six years after his conviction to move to withdraw his plea which weighs against granting the motion"); State v. Robinson, 2013-Ohio-5672, ¶ 19 (12th Dist.) (appellant waiting four years after his conviction to move to withdraw his plea "clearly militates against" granting appellant's motion to withdraw). {¶ 9} This is only compounded

11
State v. McDonaldgreen
ohioctapp · 2014 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v. Ramirez, 2019-Ohio-3050, ¶ 32 (12th Dist.) (appellant waiting nearly seven years before filing his motion to withdraw militated against granting appellant's motion); State v. Daniels, 2019-Ohio-2274, ¶ 22 (12th Dist.) ("appellant waited nearly six years after his conviction to move to withdraw his plea which weighs against granting the motion"); State v. Robinson, 2013-Ohio-5672, ¶ 19 (12th Dist.) (appellant waiting four years after his conviction to move to withdraw his plea "clearly militates against" granting appellant's motion to withdraw). {¶ 9} This is only compounded

11
State v. Danielsgreen
ohioctapp · 2019 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v. Ramirez, 2019-Ohio-3050, ¶ 32 (12th Dist.) (appellant waiting nearly seven years before filing his motion to withdraw militated against granting appellant's motion); State v. Daniels, 2019-Ohio-2274, ¶ 22 (12th Dist.) ("appellant waited nearly six years after his conviction to move to withdraw his plea which weighs against granting the motion"); State v. Robinson, 2013-Ohio-5672, ¶ 19 (12th Dist.) (appellant waiting four years after his conviction to move to withdraw his plea "clearly militates against" granting appellant's motion to withdraw). {¶ 9} This is only compounded

11
State v. Ramirezgreen
ohioctapp · 2019 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., State v. Ramirez, 2019-Ohio-3050, ¶ 32 (12th Dist.) (appellant waiting nearly seven years before filing his motion to withdraw militated against granting appellant's motion); State v. Daniels, 2019-Ohio-2274, ¶ 22 (12th Dist.) ("appellant waited nearly six years after his conviction to move to withdraw his plea which weighs against granting the motion"); State v. Robinson, 2013-Ohio-5672, ¶ 19 (12th Dist.) (appellant waiting four years after his conviction to move to withdraw his plea "clearly militates against" granting appellant's motion to withdraw). {¶ 9} This is only compounded

11
State ex rel. Special Prosecutors v. Judgesgreen
ohio · 1978 · cited in 1 Ohio opinions naming this issue, 2007–2007
1 sentence

2007Special Prosecutors , supra, at 97. {¶ 17} Moreover, even assuming the trial court had jurisdiction to consider Sanchez's motion, we find that it is barred by the doctrine of res judicata.

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. Hoskin green
ohioctapp · 2022
1 sentence

2025He asserts that he “committed all of his crimes during a short window right in the middle of his youthful years, he had limited earlier criminal history, and his PTSD and marijuana abuse were major contributing factors.” (Sanchez brief, p. 23.) He contends that “there was no factual basis for the findings made in support of consecutive sentences, either because his presumptive life prison term renders them objectively unnecessary or because the record does not show he presents a significant long-term danger to the public or requires additional punishment beyond what a concurrent sentence would

12025–2025
Jose Rosa v. Frank McCray and Eliot L. Spitzer green
ca2 · 2005
1 sentence

2022Rosa v. McCray, 396 F.3d 210 (2d Cir.2005), United States v. Sanchez, 13 F.4th 1063 (10th Cir.2021).

12022–2022
Anders v. California green
scotus · 1967
1 sentence

2017Id.

12017–2017
State v. Perry green
ohio · 1967
1 sentence

2007"Under the doctrine of res judicata , a final judgment of conviction bars a convicted defendant who was represented by counsel from raising and litigating in any proceeding, except an appeal from that judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial, which resulted in that judgment of conviction, or on an appeal from that judgment." State v. Szefcyk , 77 Ohio St.3d 93 , 1996-Ohio-337 , at syllabus, citing State v. Perry (1967), 10 Ohio St.2d 175 , at paragraph nine of the syllabus. {¶ 18} As previously noted, Sanch

12007–2007
State v. McDonald, Unpublished Decision (11-26-2004) green
ohioctapp · 2004
1 sentence

2007No. 2003-L-155, 2004-Ohio-6332 , at ¶ 22 ("[r]es judicata bars claims raised in a Crim.R. 32.1 post-sentence motion to withdraw guilty plea that were raised or could have been raised in a prior proceeding"). {¶ 19} Based on the aforementioned discussion, the trial court did not err in denying Sanchez's motion to withdraw his no contest plea.

12007–2007
State v. Szefcyk green
ohio · 1996
1 sentence

2007"Under the doctrine of res judicata , a final judgment of conviction bars a convicted defendant who was represented by counsel from raising and litigating in any proceeding, except an appeal from that judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial, which resulted in that judgment of conviction, or on an appeal from that judgment." State v. Szefcyk , 77 Ohio St.3d 93 , 1996-Ohio-337 , at syllabus, citing State v. Perry (1967), 10 Ohio St.2d 175 , at paragraph nine of the syllabus. {¶ 18} As previously noted, Sanch

12007–2007
State v. Szefcyk green
ohio · 1996
1 sentence

2007"Under the doctrine of res judicata , a final judgment of conviction bars a convicted defendant who was represented by counsel from raising and litigating in any proceeding, except an appeal from that judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial, which resulted in that judgment of conviction, or on an appeal from that judgment." State v. Szefcyk , 77 Ohio St.3d 93 , 1996-Ohio-337 , at syllabus, citing State v. Perry (1967), 10 Ohio St.2d 175 , at paragraph nine of the syllabus. {¶ 18} As previously noted, Sanch

12007–2007

Where else courts name it

CA 134 (1970–2026) TX 48 (1981–2026) WA 12 (1985–2024) FL 8 (1984–2024) NY 8 (2004–2024) OH 6 (2007–2026) NJ 6 (1979–2009) UT 5 (2015–2025) MN 4 (2012–2024) PA 4 (2017–2026) NM 4 (1982–2021) WY 4 (2010–2023) AZ 4 (1999–2018) ID 4 (2011–2026) VA 3 (2003–2009) MO 2 (2005–2008) NV 2 (2014–2016) IN 2 (2000–2006) GA 2 (2011–2020) MD 2 (1989–2011) IL 2 (2026–2026)

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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