Ohio Revised Code

Ohio Rev. Code § 2945.831 (2026)

Motion for new trial not necessary for appellate review

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A motion for a new trial is not a necessary prerequisite to obtain appellate review of the sufficiency or weight of the evidence in the trial of a criminal case.

Notes of Decisions
Cited in 4 cases (1 in the last 5 years), 1998–2022 · leading case: Eastley v. Volkman, 2012-Ohio-2179, 972 N.E.2d 517.
Eastley v. Volkman, 2012-Ohio-2179, 972 N.E.2d 517. “…to obtain appellate review of the sufficiency or weight of the evidence in the trial of a criminal case.” R.C. 2945.831.”
Gevedon v. Ivey, 876 N.E.2d 604 (Ohio Ct. App. 2d Dist. 2007). “18; R.C. 2945.831. {¶ 33} “Furthermore, the C.”
State v. Williams, 2022-Ohio-2517. “This statute, R.C. 2945.831, provides that “[a] motion for a new trial is not a necessary prerequisite to obtain appellate review of the sufficiency or weight of the evidence in the trial of a criminal case.”
Reed v. Key-Chrysler Plymouth, 708 N.E.2d 1021 (Ohio Ct. App. 2d Dist. 1998). “18; R.C. 2945.831. Furthermore, the C.E. Morris standard is a rule of such deference that it erases any distinction between review for weight of the evidence in the courts of appeals and review by the Supreme Court of matters of law.”
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