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Case CaptionCase No.Topics and IssuesAuthorCitation / CountyDecidedPostedWebCite
In re Hasenfratz L-24-1235Zmuda. Reversing trial court’s denial of appellant’s motion to quash subpoenas requesting the entirety of the Decedent’s estate planning file. Matter is remanded to the trial court for evidentiary hearing or for in camera review of the file, and for a decision as to which materials are protected, as well as which are unprotected, under the attorney-client privilege or the work-product doctrine.ZmudaLucas 7/3/2025 7/3/2025 2025-Ohio-2372
State v. Adams OT-24-019Appellant’s convictions of obstruction and failure to comply were not against the manifest weight of the evidence. The trial court did not err in not merging the separate, identifiable offenses as allied offenses. Trial court erred in failing to do mandatory R.C. 2981.09 proportionality review for the imposition of vehicle forfeiture at sentencing. Judgment affirmed, in part, and reversed, in part.OsowikOttawa 7/3/2025 7/3/2025 2025-Ohio-2371
State v. Wrosch WM-24-019Zmuda, J., writing for the majority, finds that the state introduced sufficient evidence to support appellant’s conviction. Judgment affirmed.ZmudaWilliams 7/1/2025 7/1/2025 2025-Ohio-2330
Rios v. Bassett-Bocker L-24-1046Duhart. Res judicata. Collateral estoppel/issue preclusion. Modification of custodyDuhartLucas 7/1/2025 7/1/2025 2025-Ohio-2328
State v. Williams L-24-1113Defendant’s motion to suppress was properly denied where the affidavit supporting the search warrant showed a nexus between the defendant’s criminal activity and the place to be searched. However, the trial court’s failure to notify defendant of his right to require the State to prove his guilt beyond a reasonable doubt, before accepting his plea, renders the plea invalid.OsowikLucas 7/1/2025 7/1/2025 2025-Ohio-2331
Erie Cty. Dept. of Job & Family Servs. v. Ray E-24-037Zmuda, J., writing for the majority, affirms the trial court’s order granting motion for judgment on the pleadings because the department of an unchartered county is not sui juris but reverses the trial court’s judgment dismissing the entire action when one-year period from complaint’s filing had not yet expired and claims against fictitiously named defendants remained.ZmudaErie 7/1/2025 7/1/2025 2025-Ohio-2327
State v. Himon WD-24-060Duhart. Any potential ambiguity in the trial court’s oral colloquy regarding the right not to be compelled to testify was clarified by the written plea form. Therefore, the trial court strictly complied with Crim.R. 11 in this case.DuhartWood 7/1/2025 7/1/2025 2025-Ohio-2329
Berrospi v. Michigan WD-25-040(Osowik): Where petitioner seeking a writ of habeas corpus alleged that she was incarcerated in another state, this court had no jurisdiction to adjudicate her case.OsowikWood 6/30/2025 6/30/2025 2025-Ohio-2314
Toledo v. Klink L-24-1251, L-24-1252Domestic-violence convictions were not against the manifest weight of the evidence where the trial court rejected defendant’s claim of self-defense. While defendant met her burden to produce evidence tending to show self-defense, the city also met its burden to prove beyond a reasonable doubt that defendant did not act in self-defense.MayleLucas 6/30/2025 6/30/2025 2025-Ohio-2316
State v. Snipes L-24-1293Snipes’ first and second assignments of error are not well-taken and the judgment of the Lucas County Court of Common Pleas is affirmed.SulekLucas 6/30/2025 6/30/2025 2025-Ohio-2317
State ex rel. Savage v. Tone L-25-00104Judge Duhart. Relator failed to comply with R.C. 2969.25(A) because he did not file an affidavit containing a description of each civil action or appeal of a civil action that relator has filed in the previous five years in any state or federal court.DuhartLucas 6/30/2025 6/30/2025 2025-Ohio-2318
State v. Weemes L-24-1137Sulek, J. Assault conviction was not against the manifest weight of the evidence where the State disproved defendant’s self-defense claim.SulekLucas 6/30/2025 6/30/2025 2025-Ohio-2319
State v. Dotts S-24-016Sulek, J. In an Operating a Vehicle Impaired ("OVI") prosecution, defendant’s counsel was not ineffective in failing to move for acquittal under Crim.R. 29 or identify a potential witness and the conviction was not against the weight of the evidence.SulekSandusky 6/30/2025 6/30/2025 2025-Ohio-2315
State v. Pitts OT-24-043MAYLE - Trial court did not err in denying motion for leave to file a delayed motion for a new trial where defendant failed to present clear and convincing evidence that he was unavoidably prevented from discovering new evidence within 120 days of the jury’s guilty verdict.MayleOttawa 6/27/2025 6/27/2025 2025-Ohio-2263
State v. Pettaway L-24-1154Per Mayle, J., assault and domestic violence convictions are supported by sufficient evidence where appellant caused pain and bruise by pushing wife, pulling off her glued-on wig, and throwing her to floor. Convictions are not against the manifest weight of the evidence because discrepancies between report taken by responding police officer and report wife made three days later do not discredit wife’s testimony; wife reported most details in second report to responding officer, but he did not include them.MayleLucas 6/27/2025 6/27/2025 2025-Ohio-2260
RYS Holdings, L.L.C. v. Virus Gaming Network, L.L.C. L-24-1239Per Mayle, J., trial court correctly granted appellee’s motion for summary judgment. Appellant business owner is liable under a commercial lease that names business as tenant because the lease clearly and unambiguously shows that owner signed in his personal capacity, and any dispute over the intended lessee is not material to deciding owner’s personal liability. Trial court did not alter or modify complaint to reach its decision finding owner liable.MayleLucas 6/27/2025 6/27/2025 2025-Ohio-2261
State v. Ricks L-24-1288Defendant’s claim—that his parole was improperly revoked, entitling him to be immediately released from prison—sounds in habeas corpus and, therefore, is subject to Chapter 2725 governing habeas corpus actions.MayleLucas 6/27/2025 6/27/2025 2025-Ohio-2262
State v. Rice L-24-1056Zmuda, J., writing for the majority, affirms the judgment finding the trial court properly admitted expert testimony on self-defense based on battered woman’s syndrome, and the record did not demonstrate the trial court applied an incorrect standard, as argued by the prosecution. The verdict was supported by the manifest weight of the evidence, with no reversible error in evidentiary rulings apparent in the record.ZmudaLucas 6/27/2025 6/27/2025 2025-Ohio-2264
State v. Chime WD-24-048Sulek - Defendant by virtue of being the parent of the victim is not in a “position of trust” as described in R.C. 2929.13(B)(1)(b)(vii) for purposes of allowing the trial court to sentence her to prison instead of community control upon conviction of a fourth-degree felony.SulekWood 6/27/2025 6/27/2025 2025-Ohio-2259
State v. Eames L-24-1162Trial court did not err in not merging complicity to commit felonious assault and complicity to commit kidnapping offenses; they were committed separately, with separate victims, separate harm, and thus, they were not R.C. 2941.25 allied offenses of similar import. Judgment affirmed.OsowikLucas 6/20/2025 6/20/2025 2025-Ohio-2177
State v. Lewis L-23-1289No trial court error in sentencing appellant after providing deadly and non-deadly force self-defense jury instructions and jury-convictions for felonious assault with a firearm specification and aggravated menacing. Judgment affirmed. Osowik.OsowikLucas 6/20/2025 6/20/2025 2025-Ohio-2178
State v. Bracey L-23-1213Judge Duhart. Motion to suppress. Leave to supplement. Good cause.DuhartLucas 6/17/2025 6/17/2025 2025-Ohio-2133
State v. Cordell OT-24-033Judge Duhart. An appellate court is not permitted to substitute its judgment for that of the trial court concerning the sentence that best reflects compliance with R.C. 2929.11 and 2929.12.DuhartOttawa 6/13/2025 6/13/2025 2025-Ohio-2089
State v. Smith WM-24-013Sulek, J. Trial court’s order imposing consecutive sentences is contrary to law because the court failed to make all of the necessary findings under R.C. 2929.14(C)(4).SulekWilliams 6/13/2025 6/13/2025 2025-Ohio-2090
Sczublewski v. Kroger Co. L-24-1035Per Mayle, J., piece of raised plywood duct taped to the floor and concealed by rug was not open and obvious danger to grocery-store patron. Additionally, evidence of attendant circumstances was presented to overcome open-and-obvious doctrine and two-inch rule, including that hazard was concealed by rug, employee was standing in front of obstruction, and plaintiff knew store to barricade construction hazards. Plaintiff sufficiently identified cause of fall.MayleLucas 6/6/2025 6/6/2025 2025-Ohio-2029
State v. Pitts L-24-1050Trial court did not err in finding that the state disproved appellant’s self-defense claim. Felonious assault conviction was not against the manifest weight of the evidence. Testimony pertaining to jointly stipulated medical records was not improper. Judgment affirmed.OsowikLucas 6/6/2025 6/6/2025 2025-Ohio-2030
State v. Petzke L-24-1009Duhart. Ineffective assistance of counsel. Prosecutorial misconduct. Sufficiency of the evidence challenge. Manifest weight of the evidence challenge.DuhartLucas 6/6/2025 6/6/2025 2025-Ohio-2031
State v. Williams L-24-1017Duhart. Felonious assault, self-defense, at fault for creating the situation. Manifest weight of the evidence challenge.DuhartLucas 6/6/2025 6/6/2025 2025-Ohio-2033
In re Trust of Hawkins v. Schwyn L-24-1005Zmuda, J., writing for the majority, finds that trial court did not abuse its discretion in denying appellant’s Civ.R. 60(B) motion for relief from judgment.ZmudaLucas 6/6/2025 6/6/2025 2025-Ohio-2034
State v. Owens E-23-033Sulek, J. In an aggravated murder case, the defendant was represented by competent counsel and the jury verdicts were supported by sufficient evidence and were not against the weight of the evidence. Hearsay; suppress; consciousness of guilt; inferior offense; premeditation; prosecutorial misconduct; cumulative error.SulekErie 6/6/2025 6/6/2025 2025-Ohio-2035
State v. Stultz WD-24-057Judge Duhart, appellant did not clearly and convincingly establish that the record did not support findings regarding the imposition of consecutive sentences.DuhartWood 6/6/2025 6/6/2025 2025-Ohio-2032
State v. Wadding E-24-01529-month delay in resentencing after remand does not violate Crim.R. 32(A) or due process where the defendant was ineligible to be released from prison during that time.SulekErie 5/30/2025 5/30/2025 2025-Ohio-1953
Sortino v. Calfee, Halter & Griswold, L.L.P. E-24-023Trial court properly granted appellee’s motion for class certification under Civ.R. 23(B)(3). Judgment affirmed. Osowik.OsowikLucas 5/30/2025 5/30/2025 2025-Ohio-1949
State v. Bleau L-24-1128Zmuda, J., writing for the majority, finds that appellant’s convictions were not against the manifest weight of the evidence and that the trial court did not err when it did not consider an affirmative defense appellant did not raise.ZmudaLucas 5/30/2025 5/30/2025 2025-Ohio-1951
State v. Pecina L-23-1261Sulek, J. Affirming trial court’s denial of motion to sever and admission of domestic violence and murder victim’s hearsay statements under forfeiture-by-wrongdoing exception, and holding that sufficient evidence supported the guilty verdict and conviction was not against the manifest weight of the evidence.SulekLucas 5/30/2025 5/30/2025 2025-Ohio-1952
State v. McCune OT-24-020Zmuda, J., writing for the majority, reverses the trial court’s judgment imposing consecutive sentences because the trial court did not make one of the necessary findings under R.C. 2929.14(C)(4).ZmudaOttawa 5/30/2025 5/30/2025 2025-Ohio-1950
State v. Celestine WM-24-010Duhart. Guilty Plea.Crim.R. 11. Prosecutorial Misconduct. Sentencing.DuhartWilliams 5/27/2025 5/27/2025 2025-Ohio-1905
State v. Coon OT-24-027, OT-24-028Guilty plea is knowingly, intelligently, and voluntarily made where trial court engaged in a detailed Crim.R. 11 plea colloquy, defendant demonstrated his understanding of the nature of the proceedings, the charges against him, and the potential penalties, he was not under the influence, had not been treated for mental illness, was feeling “good” mentally, and he passed two mental health screenings.SulekOttawa 5/23/2025 5/23/2025 2025-Ohio-1849
State v. Acosta L-24-1140SUMMARY: Mayle. Affirming denial of petition for postconviction relief on grounds that it was untimely filed; and affirming denial of motion for disclosure of grand jury transcripts where appellant’s challenge was to the evidence supporting the indictment.MayleLucas 5/23/2025 5/23/2025 2025-Ohio-1847
State v. Haas L-24-1217Per Mayle, J., appellant is not entitled to withdraw his plea under Crim.R. 32.1 because he failed to show manifest injustice. He was convicted of violating a protection order that was valid on the date of the violation, and petitioner’s decision to dismiss her petition—causing the common pleas court to dissolve the ex parte CPO—did not negate appellant’s failure to obey a valid court order.MayleLucas 5/23/2025 5/23/2025 2025-Ohio-1852
Haskins v. F. Leo Groff, Inc. E-24-039Duhart. Affirming entry of summary judgment in favor of appellees and against appellant in case alleging breach of real estate purchase contract and fraud.DuhartErie 5/23/2025 5/23/2025 2025-Ohio-1850
Effinger v. Vermilion Power Boats, Inc. E-24-050Duhart. Summary judgment in favor of appellee affirmed because condition upon which appellant fell was open and obvious as a matter of law.DuhartErie 5/23/2025 5/23/2025 2025-Ohio-1851
State v. Ross E-24-028Per Mayle, J., trial court did not commit plain error when instructing the jury. Appellant’s conviction of felonious assault under R.C. 2903.11(A)(1) was not against the manifest weight of the evidence, despite the victim not testifying at trial.MayleErie 5/23/2025 5/23/2025 2025-Ohio-1853
Ayers v. Ayers WD-24-061SUMMARY: Duhart. Affirming trial court’s amended order and final judgment entry of divorce imputing potential income to appellant for child-support-calculation purposes, where, on remand from the Ohio Supreme Court, the trial court expressly found appellant to be voluntarily unemployed as a condition precedent to imputing potential income.DuhartWood 5/23/2025 5/23/2025 2025-Ohio-1848
Baker v. Walmart Corp. L-24-1157Judge Duhart, failure to file transcriptDuhartLucas 5/20/2025 5/20/2025 2025-Ohio-1806
State v. Smith WM-24-018sentencingZmudaWilliams 5/20/2025 5/20/2025 2025-Ohio-1807
Foster v. Toledo City School Dist. Bd. of Edn. L-24-1068Claim against employee of a political subdivision for spoliation of evidence based on allegations that the employee returned video recordings of an accident to be taped over is a claim against her in her personal, not official, capacity.SulekLucas 5/16/2025 5/16/2025 2025-Ohio-1769
State v. Dudley L-24-1028, L-24-1029Per Mayle, J., trial court’s failure to offer prosecutor a chance to speak at sentencing, as required by Crim.R. 32(A), and failure to explain all of appellant’s appellate rights, as required by Crim.R. 32(B), did not prejudice appellant and is harmless error.MayleLucas 5/13/2025 5/13/2025 2025-Ohio-1715
State v. Rochon OT-24-040Trial court’s decision to deny limited driving privileges under R.C. 4510.021 was not an abuse of discretion following defendant’s conviction for reckless driving and speeding. Defendant was cited for driving 110 mph, into on-coming lane of traffic and in a residential area.MayleLucas 5/13/2025 5/13/2025 2025-Ohio-1716
State v. Watkins L-24-1112Osowik - Trial court did not err in rejecting non-deadly force self-defense claim. Robbery conviction was not against the manifest weight of the evidence. Parties concur, and record shows, that the trial court erred in imposing costs of confinement and supervision. Judgment affirmed, in part, and vacated, in part.OsowikLucas 5/13/2025 5/13/2025 2025-Ohio-1717
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