Ohio Rev. Code » Chapter 2945
Ohio Revised Code

Ohio Rev. Code § 2945.78 (2026)

Recording the verdict

✓ laws through the 2026 session (checked Sept. 2026)
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Effective:
October 1, 1953
Latest Legislation:
House Bill 1 - 100th General Assembly
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When the verdict given is such as the court may receive, it must be immediately entered in full upon the minutes.
Notes of Decisions
Cited in 8 cases (7 in the last 5 years), 2005–2025 · leading case: State v. Kerby, 833 N.E.2d 757 (Ohio Ct. App. 2d Dist. 2005).
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State v. Kerby, 833 N.E.2d 757 (Ohio Ct. App. 2d Dist. 2005). “If so, the time for bringing defendant to trial continued to run unabated from September 4, 2002, when the speedy-trial time resumed running, until November 12, 2002, when it elapsed.”
State v. Vulgamore, 2021-Ohio-3147. “”1 Appellant directs our attention to R.C. 2945.78 which states that “When the verdict given is such as the court may receive it, it must be immediately entered in full upon the minutes.”
State ex rel. Dodson v. Held Phipps, 2023-Ohio-3639. · cites it 3× “90CR-5725 ("Dodson I"); (2) to record and journalize the jury verdict, pursuant to R.C. 2945.78, rendered in Dodson I and State v.”
State v. Dodson, 2023-Ohio-1341. · cites it 2× “{¶ 4} On May 23, 2022, Dodson filed notices of appeal from the Franklin County Court of Common Pleas April 19, 2022 order denying his “Motion Requesting, Pursuant to R.C. §2945.78 to Record and Journalize the Kidnaping Jury Verdict’s [sic] that found Defendant not guilty of…”
State v. Kessler, 2025-Ohio-1041, 268 N.E.3d 73. · cites it 4× “22, IT DID NOT RECORD THE VERDICT IN VIOLATION OF R.C. 2945.78, IT CANNOT BE CURED BY THE RULE 9 STATEMENT, AND IT VIOLATED KESSLER’S DUE PROCESS RIGHTS UNDER THE FEDERAL AND OHIO CONSTITUTION.”
State v. Heald, 2025-Ohio-3031. “reached and returned to the trial court, violated Appellant’s rights to Due Process and to trial by jury and constituted plain error, and violated Appellant’s right against Double Jeopardy, under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and…”
State v. Dodson, 2023-Ohio-4296. · cites it 2× “{¶ 3} We have previously recounted the history of Dodson’s relevant appeals as follows: On May 23, 2022, Dodson filed notices of appeal of the Franklin County Court of Common Pleas April 19, 2022 order denying his “Motion Requesting, Pursuant to R.C. §2945.78 to Record and…”
State v. Thomann, 2022-Ohio-4264. “31(A) and R.C. 2945.78, rendering the sentence a nullity.”
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