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| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
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State v. Seffernick
| 1-24-41 | CONSECUTIVE SENTENCES; R.C. 2929.14(C)(4); MANDATORY PRISON TERMS FOR UNDERLYING FELONY OFFENSES WITH FIREARM SPECIFICATIONS; R.C. 2929.13(F)(8). The trial court made the appropriate R.C. 2929.14(C)(4) findings necessary to impose consecutive sentences and the record supports the trial court’s findings. The trial court correctly applied R.C. 2929.13(F)(8) and imposed mandatory prison terms on the underlying felonious-assault offenses that included firearm specifications. | Zimmerman | Allen |
6/30/2025
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6/30/2025
| 2025-Ohio-2292 |
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State v. Worthen
| 1-24-71 | Obstructing Official Business; R.C. 2921.31(A); No-Contest Plea; Explanation of the Circumstances; Crim.R. 11(E). Defendant-appellant's conviction for obstructing official business, following his no-contest plea, was supported by sufficient evidence. The trial court did not fail to comply with the relevant provision of Crim.R. 11 in accepting defendant-appellant's no-contest plea. The trial court did not err by imposing both jail time and a fine for a misdemeanor. | Miller | Allen |
6/30/2025
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6/30/2025
| 2025-Ohio-2293 |
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State v. Poth
| 3-24-08 | Crim.R. 11(C)(2)(a); Plea Colloquy. Defendant-appellant did not show he was prejudiced by the trial court's alleged failure to comply with Crim.R. 11(C)(2)(a), so he is not entitled to have his guilty plea vacated for the alleged failure to comply. | Miller | Crawford |
6/30/2025
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6/30/2025
| 2025-Ohio-2294 |
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State v. Woods
| 3-24-31 | Jail Uniform; Ineffective Assistance of Counsel. Although the best practice is to place on the record an explanation for why a defendant is appearing in the jail uniform for trial, the failure to do so is not reversible error. Counsel was not ineffective for allowing the defendant to wear the jail uniform because a review of the evidence shows that the overwhelming weight of the evidence supported conviction. As a result, the outcome of the trial was unlikely to be different if the defendant was wearing street clothes rather than the jail uniform. | Willamowski | Crawford |
6/30/2025
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6/30/2025
| 2025-Ohio-2295 |
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State v. Wilson
| 6-24-12 | KNOWING, INTELLIGENT, AND VOLUNTARY PLEA; CRIM.R. 11; R.C. 2941.25; MERGER. The defendant-appellant’s guilty pleas were knowing, intelligent, and voluntary. The trial court strictly complied with Crim.R. 11(C)(2)(c) and advised the defendant-appellant of the privilege against self-incrimination prior to accepting her guilty pleas. The trial court substantially complied with Crim.R. 11(C)(2)(b) when it informed the defendant-appellant of and determined that she understood the effect of her guilty pleas. The trial court erred by not merging the defendant-appellant’s convictions for strangulation and domestic violence as allied offenses of similar import. | Zimmerman | Hardin |
6/30/2025
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6/30/2025
| 2025-Ohio-2296 |
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In re G.D.S.
| 7-24-10 | ABUSE OF DISCRETION; TRANSCRIPT OF PROCEEDINGS. The juvenile court did not abuse its discretion by adopting the magistrate’s decision. In ruling on the appellant’s objections to the magistrate’s decision, the juvenile court properly relied on the magistrate’s factual findings in the absence of a transcript of the proceedings before the magistrate for review. | Zimmerman | Henry |
6/30/2025
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6/30/2025
| 2025-Ohio-2297 |
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In re A.B.
| 10-24-08 | Permanent Custody; Manifest Weight of the Evidence; Legal Custody. Trial court's decision to grant the Agency's motion for permanent custody was not against the weight of the evidence when the child had been in the temporary custody of the Agency for more than 12 out of a consecutive 22 month period and the evidence showed it was in the child's best interest. Trial court did not err in denying the motion to grant legal custody to the paternal grandmother when the foster family, who wished to adopt were maternal relatives. | Willamowski | Mercer |
6/30/2025
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6/30/2025
| 2025-Ohio-2298 |
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Frankart v. Phillips
| 13-24-36 | CHILD CUSTODY; PARENT-NONPARENT CUSTODY DISPUTE; LEGAL CUSTODY; R.C. 2151.23(A)(2); PARENTAL FITNESS AND SUITABILITY; DETRIMENT TO THE CHILD; WELFARE OF THE CHILD. The trial court did not abuse its discretion by denying the grandfather’s motion for legal custody and by designating the mother as the child’s residential parent and legal custodian. | Waldick | Seneca |
6/30/2025
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6/30/2025
| 2025-Ohio-2299 |
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State v. Baker
| 13-24-42 | NOT GUILTY BY REASON OF INSANITY DEFENSE; MANIFEST WEIGHT OF THE EVIDENCE; WITNESS CREDIBILITY; COMPETING EXPERTS; INEFFECTIVE ASSISTANCE; CALLING A WITNESS TO TESTIFY. The defendant-appellant’s aggravated murder and kidnapping convictions are not against the manifest weight of the evidence because the jury did not lose its way in concluding that the defendant-appellant was capable of understanding the wrongfulness of his conduct at the time of the offenses at issue in this case. The defendant-appellant’s trial counsel was not ineffective for failing to call his treating physician to testify at trial. | Zimmerman | Seneca |
6/16/2025
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6/16/2025
| 2025-Ohio-2107 |
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State v. Smith
| 8-24-26; 8-24-27 | Because the defendant-appellant failed to assign any error as to case number CR23 07 0173, assigned appellate case number 8-24-26, or case number CR23 09 0211, assigned appellate case number 8-24-27, those appellate cases were dismissed. | Zimmerman | Logan |
6/16/2025
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6/16/2025
| 2025-Ohio-2104 |
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State v. Smith
| 8-24-28 | DRIVE BY FIREARM SPECIFICATION; R.C. 2941.146; FELONIES COMMITTED AS PART OF THE SAME ACT OR TRANSACTION. The defendant-appellant’s sentence is not contrary to law because the conduct underlying each drive-by specification was not committed as part of the same act or transaction. | Zimmerman | Logan |
6/16/2025
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6/16/2025
| 2025-Ohio-2105 |
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State v. Bible
| 8-24-45 | Ineffective assistance of counsel; Mandatory drug fines. Counsel's failure to file an affidavit of indigency on defendant-appellant's behalf with respect to the mandatory drug fines constituted ineffective assistance of counsel as there was a reasonable probability that the defendant-appellant would have been found indigent. | Waldick | Logan |
6/16/2025
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6/16/2025
| 2025-Ohio-2106 |
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State v. Johnson
| 1-24-38 | Felonious Assault; Sufficiency; Ineffective Assistance. Evidence was sufficient to establish that defendant "knowingly" caused serious physical harm to corrections officer. Defendant did not establish ineffective assistance of counsel. | Waldick | Allen |
6/16/2025
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6/16/2025
| 2025-Ohio-2103 |
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State v. Craft
| 3-23-44 | Plain error; Evidence; Due Process; Polygraph Examination; Cumulative Error Doctrine; Merger. The trial court did not commit plain error by permitting evidence that defendant-appellant was asked to submit to a polygraph examination. The trial court did not commit plain error by permitting evidence that the defendant-appellant did not voluntarily provide law enforcement with the passcode to unlock his phone. Because the trial court did not commit multiple errors at defendant’s trial, the cumulative-error doctrine does not apply. The trial court did not err by failing to merge defendant-appellant’s convictions for felonious assault and discharging a firearm at or into a habitation. | Miller | Crawford |
6/9/2025
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6/9/2025
| 2025-Ohio-2045 |
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Dunlap v. NeXus RV, L.L.C.
| 1-24-65 | Civ.R. 54(B); Motion to Dismiss; Timely Appeal; App.R. 4. Appellate courts in Ohio have jurisdiction to review final, appealable orders that are issued by a trial court from within their district. Further, for a reviewing court to have jurisdiction to review a final order, a notice of appeal must be filed within thirty days of the issuance of the relevant judgment entry pursuant to App.R. 4(A). In certain circumstances, an order that resolves less than all of the claims in an action may be rendered final and appealable if a trial court includes the required language set forth in Civ.R. 54(B). App.R. 4(B)(5) indicates that the requirements defining a timely appeal in App.R. 4(A) apply to orders that are rendered final and appealable through the use of the language set forth in Civ.R. 54(B). | Willamowski | Allen |
6/2/2025
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6/2/2025
| 2025-Ohio-1969 |
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In re S.F.
| 8-24-09 | Protective Supervision, Moot, Expiration of Time. Case must be dismissed as the protective supervision had expired prior to appeal and the record does not show that the case remained active. | Willamowski | Logan |
6/2/2025
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6/2/2025
| 2025-Ohio-1970 |
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State v. Yemsvat
| 8-24-48 | Misdemeanor Sentencing; R.C. 2929.21; R.C. 2929.22(B) Factors. R.C. 2929.21(A) lists the overriding purposes of misdemeanor sentencing. Appellate courts review misdemeanor sentences under an abuse of discretion standard. A trial court is not required to state its reasons for imposing a misdemeanor sentence. | Willamowski | Logan |
6/2/2025
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6/2/2025
| 2025-Ohio-1971 |
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State v. Melendez
| 9-24-34 | COMPETENCY TO STAND TRIAL; R.C. 2945.37; R.C. 2945.38(C); INEFFECTIVE ASSISTANCE. The trial court’s failure to conduct a competency restoration hearing was harmless error because the record lacks sufficient indicia of the defendant-appellant’s incompetency. The trial court did not abuse its discretion by failing to sua sponte order a competency evaluation. The trial court’s failure to dismiss the indictment in this case did not constitute plain error. The defendant-appellant’s trial counsel was no ineffective for failing to file a motion to dismiss the indictment for violating the one-year period under R.C. 2945.38, challenge his competency, or move for a mistrial or request a curative instruction at his second trial despite his repeated disruptions. | Zimmerman | Marion |
6/2/2025
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6/2/2025
| 2025-Ohio-1972 |
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State v. Harvey
| 9-24-27 | MANIFEST WEIGHT OF THE EVIDENCE; TAMPERING WITH EVIDENCE. The defendant-appellant’s tampering with evidence conviction is not against the manifest weight of the evidence. | Zimmerman | Marion |
5/27/2025
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5/27/2025
| 2025-Ohio-1889 |
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Maynard v. Barkley
| 9-24-41 | Forcible Entry and Detainer; Jury Deposit; Local Rule; Part Performance; Promissory Estoppel; Statute of Frauds. Under the statute of frauds, contracts for the sale of land are to be in writing and signed by the party to be charged therewith. However, an oral land contract can be removed from the statute of frauds under the doctrine of part performance if there are unequivocal acts based upon the agreement; the party has changed its position to its detriment; and it is impractical to return to the parties to the previous status quo. If the acts of the parties can be reasonably explained by another arrangement, the doctrine of part performance is not applicable. The doctrine of promissory estoppel can remove an oral agreement from the statute of frauds if there was a misrepresentation that the statute of fraud's requirements were met or a promise to make a memorandum of the agreement. | Willamowski | Marion |
5/27/2025
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5/27/2025
| 2025-Ohio-1890 |
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Baughman v. Baughman
| 11-24-06 | Final Order; R.C. 2505.02. The judgment entry from which Appellants appealed was not a final order, so the appeal is dismissed for lack of jurisdiction. | Miller | Paulding |
5/27/2025
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5/27/2025
| 2025-Ohio-1891 |
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In re Baughman Irrevocable Trust
| 11-24-07 | Jurisdictional Priority Rule; Whole-Issue Exception; Civ.R. 12(B)(1) Motion. Appellate Courts apply a de novo standard of review in determining whether a trial court correctly applied the jurisdictional priority rule. The jurisdictional priority rule exists to prevent inconsistent rulings and to promote judicial economy. The jurisdictional priority rules generally applies where the same parties and the same causes of action are present in pending cases filed in two different state courts of concurrent jurisdiction. In such a situation, the first court to have its jurisdiction invoked over the matter has exclusive jurisdiction under the jurisdictional priority rule. However, under the whole issue exception, the causes of action do not need to be the same for the jurisdictional priority rule to apply. The whole issue exception applies where (1) cases are pending in two different courts of concurrent jurisdiction and (2) a ruling from the second action could affect or interfere with the resolution of the issues in the first case. | Willamowski | Paulding |
5/27/2025
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5/27/2025
| 2025-Ohio-1892 |
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Fifth Third Bank v. Martinez
| 13-24-44 | Summary Judgment; Civ.R. 56. Trial court properly granted summary judgment in favor of bank where defendant produced no evidence whatsoever to support his claims in response to summary judgment. | Waldick | Seneca |
5/27/2025
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5/27/2025
| 2025-Ohio-1893 |
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State v. Gross
| 14-24-34 | Felony Sentencing; R.C. 2929.11; R.C. 2929.12. Defendant-appellant's prison sentence is not clearly and convincingly contrary to law. | Miller | Union |
5/27/2025
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5/27/2025
| 2025-Ohio-1894 |
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State v. Heckler
| 7-24-08 | Judicial Disqualification; Manifest Weight; R.C. 2929.14(C)(4). We lack jurisdiction to consider whether a trial judge should be disqualified; however, to the extent that appellant makes due process arguments, they are not supported by the record to demonstrate bias. Convictions were not against the manifest weight of the evidence. Appellant did not demonstrate that his consecutive sentences were clearly and convincingly contrary to law. | Waldick | Henry |
5/27/2025
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5/27/2025
| 2025-Ohio-1888 |
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In re Adoption of V.C.
| 5-24-37 | Parental consent to adoption; R.C. 3107.07; R.C. 3107.11; Failure to object to adoption; App.R. 9; Failure of appellant to provide transcript on appeal. The trial court's judgment finding the mother's consent to adoption was not required is affirmed on two bases: (1) the mother-appellant failed to include a transcript of the consent hearing in the record on appeal, and (2) the mother-appellant failed to file a timely objection to the adoption in the trial court, as required by statute. | Waldick | Hancock |
5/27/2025
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5/27/2025
| 2025-Ohio-1887 |
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Souders v. U.S. Bank Natl. Assn.
| 14-24-27 | Civ.R. 60(B); Motion for Relief from Judgment; Abuse of Discretion; Timely Appeal. A Civ.R. 60(B) motion for relief from judgment is not a substitute for direct appeal. A litigant may not use a Civ.R. 60(B) motion to raise arguments that were available on direct appeal from the judgment. Appellate courts review a trial court's decision on Civ.R. 60(B) motion for an abuse of discretion. Further, a litigant that fails to file a timely notice of appeal fails to invoke the jurisdiction of the appellate court. | Willamowski | Union |
5/19/2025
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5/19/2025
| 2025-Ohio-1781 |
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Conrad v. Hamrick
| 10-24-07 | DEFAULT JUDGMENT; CIV.R. 55; CIV.R. 6(B); EXCUSABLE NEGLECT. The trial court did not abuse its discretion by denying the plaintiff-appellant’s motion for default judgment after granting the defendants-appellees leave to file a late answer because the surrounding facts and circumstances of the case reflect that the defendants-appellees demonstrated excusable neglect. | Zimmerman | Mercer |
5/19/2025
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5/19/2025
| 2025-Ohio-1773 |
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State v. Pullom
| 13-24-28 | Motion to Suppress Evidence. The trial court did not err by denying defendant-appellant's motion to suppress evidence. | Miller | Seneca |
5/12/2025
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5/12/2025
| 2025-Ohio-1700 |
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State v. Pullom
| 13-24-29 | Motion to Suppress Evidence. The trial court did not err by denying defendant-appellant's motion to suppress evidence. | Miller | Seneca |
5/12/2025
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5/12/2025
| 2025-Ohio-1701 |
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In re C.Z.
| 10-24-04, 10-24-05, 10-24-06 | Permanent Custody; Best Interests; R.C. 2151.4117. Trial court's grant of permanent custody to agency was supported by clear and convincing evidence. Parents did not demonstrate plain error regarding any noncompliance with R.C. 2151.4117. | Waldick | Mercer |
5/12/2025
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5/12/2025
| 2025-Ohio-1699 |
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State v. Combs
| 14-24-31 | Consecutive Sentences; Mandatory Sentences. Trial court did not err in imposing consecutive sentences when the idoneous findings were made by the trial court. The trial court correctly ordered the convictions for third degree felonies for aggravated trafficking in drugs were mandatory when R.C. 2925.03(C)(1)(c) required them to be mandatory due to Combs having three prior felony drug abuse offenses. | Willamowski | Union |
5/12/2025
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5/12/2025
| 2025-Ohio-1702 |
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State v. Browne
| 6-24-13 | SENTENCING; REAGAN TOKES ACT; R.C. 2929.19(B)(2)(c). Because the trial court failed to provide the mandatory Reagan Tokes notifications as provided under R.C. 2929.19(B)(2)(c) at the defendant-appellant’s sentencing hearing, the defendant-appellant’s sentence is contrary to law and not authorized by law. | Zimmerman | Hardin |
5/12/2025
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5/12/2025
| 2025-Ohio-1697 |
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Kern v. Mishler
| 8-24-38 | SUMMARY JUDGMENT; STATUTE OF LIMITATIONS; DISCOVERY RULE; PUNITIVE DAMAGES; ACTUAL MALICE; JURY INSTRUCTION; ATTORNEY FEES; MANIFEST WEIGHT OF THE EVIDENCE; COMPENSATORY DAMAGES. The trial court did not err by granting (partial) summary judgment in favor of defendants-appellees as to the plaintiff-appellant’s claims because the plaintiff-appellant’s claims are time-barred by the applicable statute of limitations. The trial court’s punitive damages jury instruction on actual malice was not plain error. The trial court did not abuse its discretion in its attorney fee award. The jury’s compensatory damages award is not against the manifest weight of the evidence. | Zimmerman | Logan |
5/12/2025
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5/12/2025
| 2025-Ohio-1698 |
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State v. Hooper
| 1-24-44 | PETITION FOR POST-CONVICTION RELIEF; R.C. 2953.21; SUBSTANTIVE GROUNDS FOR RELIEF. The trial court did not abuse its discretion by dismissing the defendant-appellant’s petition for post-conviction relief without a hearing. The trial court properly considered the entirety of the record, including the proffered evidence outside the record related to the defendant-appellant’s claim of ineffective assistance of trial counsel, and determined that the defendant-appellant failed to present substantive grounds for relief. | Zimmerman | Allen |
5/5/2025
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5/5/2025
| 2025-Ohio-1594 |
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State v. Groh
| 4-24-21 | Gross Sexual Imposition; R.C. 2907.05(A)(4); Indictment; Consecutive Sentences; R.C. 2929.14(C)(4)(c). Defendant-appellant's convictions for gross sexual imposition were supported by sufficient evidence, were not against the manifest weight of the evidence, and did not violate the Due Process Clause. The trial court's decision to run the sentences for each conviction consecutively was not contrary to law. | Miller | Defiance |
4/28/2025
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4/28/2025
| 2025-Ohio-1497 |
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State v. Goralczyk
| 3-24-01 | Sufficiency of the Evidence; Manifest Weight; Burglary; Theft; Menacing. The evidence was not sufficient to support a conviction for burglary when there was no evidence of the intent to commit a criminal offense. The conviction for burglary was against the manifest weight of the evidence. However, the evidence was sufficient to support a conviction for the lesser included offense of trespass in a habitation. Matter reversed and remanded for trial court to vacate the burglary conviction and to find defendant guilty of the lesser included offense and to sentence appropriately. | Willamowski | Crawford |
4/21/2025
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4/21/2025
| 2025-Ohio-1408 |
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State v. Carnes
| 3-24-06 | Evid.R. 404; Ineffective Assistance; Cumulative Error. Trial court did not err by admitting evidence; defendant did not establish any prejudicial error, let alone cumulative error. | Waldick | Crawford |
4/21/2025
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4/21/2025
| 2025-Ohio-1409 |
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State v. Godsey
| 1-24-60 | R.C. 2929.141(A); post-release control. Trial court could not impose remaining prison time from post-release control for a violation of community control; rather, the trial court had to impose the PRC time at sentencing on the new felony. | Waldick | Allen |
4/21/2025
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4/21/2025
| 2025-Ohio-1407 |
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State v. Williams
| 8-24-44 | Jail-time Credit; Res Judicata. Appellant did not demonstrate any miscalculation of jail-time credit. Further, his categorical arguments are barred by res judicata. | Waldick | Logan |
4/21/2025
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4/21/2025
| 2025-Ohio-1411 |
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In re Z.W.
| 5-24-18, 5-24-19, 5-24-20, 5-24-21 | Permanent custody; In camera interview; Manifest weight of the evidence. The trial court's permanent custody decisions were supported by clear and convincing evidence. | Waldick | Hancock |
4/21/2025
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4/21/2025
| 2025-Ohio-1410 |
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State v. Durst
| 13-24-32 | Res Judicata. Defendant's arguments barred by res judicata. | Waldick | Seneca |
4/21/2025
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4/21/2025
| 2025-Ohio-1412 |
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State v. Parsons
| 9-24-16 | Sexual Battery; R.C. 2907.03(A)(5); Fines; R.C. 2953.08(G). Defendant-appellant's conviction was not against the manifest weight of the evidence. The trial court's imposition of a $10,000 fine, in addition to a prison term, did not violate defendant-appellant's constitutional rights. | Miller | Marion |
4/14/2025
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4/14/2025
| 2025-Ohio-1324 |
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State v. Stephens
| 5-24-31 | Felony sentencing review; R.C. 2953.08; R.C. 2929.11; R.C. 2929.12. The prison sentence imposed by the trial court was not clearly and convincingly contrary to law. | Waldick | Hancock |
4/14/2025
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4/14/2025
| 2025-Ohio-1322 |
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State v. Thomas
| 1-24-29 | Evid.R. 404(B); Other Crimes, Wrongs, or Acts; Aggravated Funding of Drug Trafficking; R.C. 2925.05(A). Text messages did not constitute evidence of any other crime, wrong, or act and, therefore, fell outside the scope of Evid.R. 404(B), so the trial court did not deny defendant-appellant a fair trial by not barring admission of the text messages based on Evid.R. 404(B). There was insufficient evidence to sustain defendant-appellant's conviction for aggravated funding of drug trafficking and, therefore, that conviction must be vacated. | Miller | Allen |
4/14/2025
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4/14/2025
| 2025-Ohio-1321 |
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State v. McLaurin
| 1-24-28 | INEFFECTIVE ASSISTANCE OF COUNSEL; R.C. 2901.05; R.C. 2901.09; SELF-DEFENSE CLAIM; CASTLE DOCTRINE. In the absence of any evidence of an unlawful entry on the part of the victim, the defendant-appellant’s trial counsel was not ineffective for failing to request a jury instruction on the castle doctrine. | Zimmerman | Allen |
4/7/2025
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4/7/2025
| 2025-Ohio-1213 |
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State v. Storer
| 2-24-07; 2-24-08 | Consecutive Sentences, R.C. 2929.11, R.C. 2929.12, R.C. 2929.14. Trial court considered the purposes and principles of sentencing and also the required statutory factors. Appellate courts lack the authority to review the conclusions the trial court reaches. Record supported trial court's findings regarding consecutive sentences. | Willamowski | Auglaize |
4/7/2025
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4/7/2025
| 2025-Ohio-1214 |
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In re K.F.
| 5-24-29 | SERIOUS YOUTHFUL OFFENDER; BLENDED SENTENCE; DELINQUENCY ADMISSION; JUV.R. 29; R.C. 2152.13(D)(3); ADULT PORTION OF SERIOUS YOUTHFUL OFFENDER’S SENTENCE; CONSECUTIVE SENTENCES; R.C. 2929.14(C)(4); CONSECUTIVE INDEFINITE SENTENCES; R.C. 2929.144. The adjudicated delinquent child-appellant’s delinquency admissions were knowing, intelligent, and voluntary because, based on the totality of the circumstances, the juvenile court substantially complied with the requirements of Juv.R. 29(D)(2). The juvenile court erred by imposing consecutive sentences because it did not make any of the three statutorily required findings before imposing consecutive sentences, either at the sentencing hearing or within the sentencing entry. The adjudicated delinquent child-appellant’s sentence is also contrary to law because the trial court imposed consecutive indefinite sentences in contravention of R.C. 2929.144. | Zimmerman | Hancock |
4/7/2025
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4/7/2025
| 2025-Ohio-1216 |
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State v. Carter
| 5-24-35 | Sentencing; Contrary to Law; Information at Sentencing; R.C. 2953.08. At sentencing, a trial court is to examine the character and history of the defendant. The information presented to a trial court at sentencing need not be limited to evidence that relates to the offenses that yielded convictions. A trial court may consider pending charges as these are required to be included in the presentence investigation report. | Willamowski | Hancock |
4/7/2025
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4/7/2025
| 2025-Ohio-1217 |
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State v. Risner
| 6-24-08, 6-24-09 | R.C. 2941.51(D); Court-Appointed-Counsel Fees; Civil Assessment; Future Ability to Pay; Abuse of Discretion; State v. Taylor, 2020-Ohio-6786. A trial court may not order a defendant to pay court-appointed-counsel fees as a part of his or her sentence. Rather, a trial court may issue a civil assessment for court-appointed-counsel fees. A trial court may, pursuant to R.C. 2941.51(D), assess some or all of the court-appointed-counsel fees incurred during a defendant's representation. A trial court may assess court-appointed-counsel fees if the defendant is found to have a present or future ability to pay these costs. Appellate courts review the imposition of court-appointed-counsel fees as a civil assessment under an abuse of discretion standard. | Willamowski | Hardin |
4/7/2025
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4/7/2025
| 2025-Ohio-1218 |
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