| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
|
State v. Humphreys
| 2025-CA-9 | Appellant’s statutory and constitutional rights to a speedy trial were not violated. The trial court did not commit plain error by failing to remove two jurors for cause on grounds of bias, and appellant’s trial counsel did not provide ineffective assistance by failing to challenge the jurors in question. Appellant’s convictions for attempted rape, kidnapping, and strangulation were supported by sufficient evidence and were not against the manifest weight of the evidence. The trial court violated Evid.R. 404(B) by allowing the State to present other-acts evidence of appellant’s prior juvenile adjudication for attempted rape. That error was harmless as to appellant’s convictions for kidnapping and strangulation, but not as to appellant’s attempted rape conviction. Because the other-acts evidence error was reversible error as to appellant’s attempted rape conviction, the sexually violent predator specification attached to that conviction must be reversed. The issue of whether appellant was guilty of the sexual motivation specification attached to his kidnapping offense should have been determined by the jury as opposed to the trial court; however, that error was invited by appellant and did not amount to plain error. The sexually violent predator specification attached to appellant’s kidnapping offense was supported by sufficient evidence and was not based on inadmissible hearsay. Appellant’s claim that the trial court erred by failing to merge his attempted rape and kidnapping convictions at sentencing is moot by virtue of the attempted rape conviction being reversed. Appellant’s claim that he was denied a fair trial due to the cumulative error committed during his trial lacks merit. Judgment affirmed in part and reversed in part. | Hanseman | Clark |
2/6/2026
|
2/6/2026
| 2026-Ohio-373 |
|
State v. Smith
| 2025-CA-41 | Appellant contends that she received ineffective assistance of counsel because her attorney did not inform her that upon her guilty pleas, she forfeited her right to appeal the trial court’s motion to suppress decision. Because the appellate record does not include the discussions between appellant and counsel concerning the guilty plea and the record is otherwise silent on the issue, a finding of ineffective assistance of counsel is not possible. Judgment affirmed. | Tucker | Clark |
2/6/2026
|
2/6/2026
| 2026-Ohio-378 |
|
State v. Pigg
| 2025-CA-44 | The trial court erred in sentencing appellee to serve a four-month jail term for fifth-degree felony aggravated possession of drugs. Absent the imposition of community control sanctions, the sentence is below the prescribed statutory range for fifth-degree felonies, and by imposing a sentence contrary to law, the trial court committed plain error. Appellee’s completion of the four-month jail sentence did not render the appeal moot because the appeal was timely filed by the State, and the State has an effective remedy through the resentencing of appellee on remand. Judgment vacated as to appellee’s sentence and remanded for resentencing. (Huffman, J., concurring.) | Hanseman | Greene |
2/6/2026
|
2/6/2026
| 2026-Ohio-375 |
|
State v. Adams
| 30520 & 30527 | Appellant’s convictions for failure to stop at a railroad grade crossing and endangering children are supported by sufficient evidence and are not against the manifest weight of the evidence. The trial court properly applied R.C. 4511.63 in convicting appellant of failure to stop at a railroad grade crossing. Judgment affirmed. | Huffman | Montgomery |
2/6/2026
|
2/6/2026
| 2026-Ohio-372 |
|
In re C.C.
| 30542 | The trial court abused its discretion by denying the State’s motion for access to recorded phone calls at a juvenile detention center where the juvenile failed to raise any expectation of privacy in the recorded phone calls and the trial court found that it was in the interest of public safety to locate the stolen firearms. Judgment reversed to the extent that it overruled the State’s motion but affirmed in all other respects. | Lewis | Montgomery |
2/6/2026
|
2/6/2026
| 2026-Ohio-374 |
|
State v. Skirvin
| 30462 | Appellant’s convictions for three counts of felonious assault on a peace officer and one count of aggravated possession of drugs were based on sufficient evidence and were not against the manifest weight of the evidence. The jury reasonably concluded that appellant knowingly attempted to cause physical harm when he shot in the direction of officers parked along the highway median, that appellant was conscious and had acted voluntarily when he drove his pickup truck into an occupied police cruiser, and that he knowingly possessed the methamphetamine found in his truck. The trial court did not abuse its discretion in failing to provide, sua sponte, a “blackout” jury instruction and in denying appellant’s request for an instruction on aggravated menacing as to the shooting. Judgment affirmed. | Epley | Montgomery |
2/6/2026
|
2/6/2026
| 2026-Ohio-376 |
|
State v. Slaughter
| 30589 | Appellant entered a valid guilty plea under Crim.R. 11, and the trial court did not abuse its discretion by overruling his motion to withdraw it. Appellant’s sentence is contrary to law, however, insofar as the trial court disapproved shock incarceration or placement in an intensive program prison without providing factual reasons for its disapproval. Judgment affirmed in part, reversed in part, and case remanded for resentencing. | Tucker | Montgomery |
2/6/2026
|
2/6/2026
| 2026-Ohio-377 |
|
Beavers v. State
| 30540 | The trial court erred by making credibility determinations in its decision granting summary judgment in favor of the State on appellant’s wrongful imprisonment claim. Judgment reversed. | Lewis | Montgomery |
1/30/2026
|
1/30/2026
| 2026-Ohio-285 |
|
State v. Finley
| 30505 | In this appeal concerning the trial court’s decision overruling appellant’s motion to dismiss his indictment, Appellant forfeited his only argument on appeal by not raising it in the trial court. Judgment affirmed. | Lewis | Montgomery |
1/30/2026
|
1/30/2026
| 2026-Ohio-287 |
|
In re A.S.
| 30567 | The trial court did not err in awarding the appellee, a public children services agency, permanent custody of appellant’s child without finding that the child could not or should not be placed with either parent within a reasonable time. The child had been in appellee’s temporary custody for 12 or more months of a 22-month period, so by statute, the trial court was not required to render a finding on the child’s placement with either parent. Likewise, the trial court did not err in failing to make a factual finding that would have supported a determination regarding the child not being placed with either parent within a reasonable time. Because the trial court was not obligated to make a finding regarding the child’s placement with either parent, the alleged absence of admissible evidence to support such a finding is immaterial. Finally, appellant cannot demonstrate entitlement to reunification with her child absent any reversible error in the trial court’s determination that awarding permanent custody to appellee was in the child’s best interest. Judgment affirmed. | Tucker | Montgomery |
1/30/2026
|
1/30/2026
| 2026-Ohio-288 |
|
Bright v. Mao
| 2025-CA-32 | Res judicata precludes appellant from arguing that the judgment on her legal separation, parts of which were incorporated into the divorce judgment on appeal in this case, was void where she failed to prosecute her appeal in the separation action. The trial court’s alleged denial of appellant’s post-judgment motion requesting a transcript of the final divorce hearing at the State’s expense is not properly before this court. Judgment affirmed. | Lewis | Greene |
1/30/2026
|
1/30/2026
| 2026-Ohio-286 |
|
State v. Wagner
| 2025-CA-33 | Appellant’s sentence to community control sanctions is not contrary to law, and the court complied with R.C. 2929.11 in imposing sentence. Judgment affirmed. | Huffman | Greene |
1/30/2026
|
1/30/2026
| 2026-Ohio-289 |
|
State v. Bell
| 30545 | Appellant’s motion to preserve biological evidence is not necessary or justiciable, and it is barred by res judicata. Judgment affirmed. | Huffman | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-202 |
|
State v. Coleman
| 30479 | The trial court erred in overruling appellant’s motion to suppress because the arresting officer lacked reasonable, articulable suspicion to stop appellant for a red-light violation. Appellant’s argument regarding her ALS appeal—which the trial court never ruled on—is moot because upon reversal and remand for the suppression issue, this matter is restored to its pre-plea status. Judgment reversed and remanded. | Huffman | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-203 |
|
Credit Serv. Internatl. v. Armstrong
| 30616 | The trial court did not err by failing to provide analysis in support of its summary judgment ruling in favor of appellee. The record does not reflect that the trial court did anything to preclude appellant from conducting discovery or being heard in opposition to summary judgment. A Dayton ordinance limiting the late fees that a landlord may charge had no applicability to appellant’s lease of an apartment in Moraine. Judgment affirmed. | Tucker | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-204 |
|
Geisenfeld v. Geisenfeld
| 30487 | The trial court did not err in finding that appellant had fraudulently induced appellee to sign a settlement agreement. The agreement was ambiguous, and therefore the court was allowed to hear extrinsic evidence. Upon consideration of that evidence, the court found that appellant acted maliciously and violated her fiduciary duty by failing to disclose that the items for which appellee had bargained under the agreement were wholly meaningless, worthless, or non-existent. No error occurred in that regard. The court also did not abuse its discretion in awarding damages and attorney fees to appellee. Judgment affirmed. | Hanseman | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-205 |
|
State v. Johnson
| 30536 | The trial court did not err in overruling appellant’s motion to dismiss his indictment on statutory and constitutional speedy trial grounds. Judgment affirmed. | Tucker | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-206 |
|
McManus v. Villalva
| 30551 | Appellant’s claim that he is redeeming real estate subject to foreclosure proceedings is unrelated to the judgment on appeal, which granted foreclosure on the subject property. Although appellant may redeem the property by paying delinquent taxes after foreclosure but prior to confirmation of a sheriff’s sale, the post-foreclosure redemption process is separate from the foreclosure order itself. Judgment affirmed. | Tucker | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-207 |
|
Reilly v. Rastegar
| 30464 | The trial court erred in granting summary judgment in favor of appellee-hospital on appellant’s respondeat superior claim in her medical negligence action. Expert testimony is not required in a negligence action involving conduct within the common knowledge and experience of jurors, which includes a hospital staff member failing to follow orders of a physician. Genuine issues of material fact precluding summary judgment remained where there was evidence that defendant-surgeon had instructed defendant-surgical scrub technician not to place a particular instrument on his surgical tray, and the surgical scrub technician failed to follow the order, ultimately handing the wrong instrument to the surgeon during appellant’s surgery. The surgeon used the instrument, and appellant was injured. Judgment reversed and remanded. | Huffman | Montgomery |
1/23/2026
|
1/23/2026
| 2026-Ohio-208 |
|
Discover Bank v. Hanson
| 30515 | The records submitted in support of appellee bank’s motion for summary judgment were properly authenticated as business records and appropriately considered by the trial court. The records established appellee’s entitlement to judgment as a matter of law on the balance appellant owed on a delinquent credit card account. Judgment affirmed. | Lewis | Montgomery |
1/16/2026
|
1/16/2026
| 2026-Ohio-140 |
|
State v. Edwards
| 30448 | Appellant’s conviction for violating a protection order was based on sufficient evidence and was not against the manifest weight of the evidence. The evidence supported the conclusions that appellant was informed of the protection order and that he was served with it before the alleged violation. The trial court appropriately acted within its discretion to credit the complainant’s testimony that appellant was the helmeted motorcyclist who followed and gestured toward the complainant. Judgment affirmed. | Hanseman | Montgomery |
1/16/2026
|
1/16/2026
| 2026-Ohio-141 |
|
In re M.A.
| 30586 | The juvenile court did not abuse its discretion in overruling Mother’s objections to a magistrate’s decision that found her infant son to be an abused child. The court did not err in admitting a drug screen record. Counsel for Mother stipulated to the authenticity of the record, and it was authenticated pursuant to R.C. 2317.422(A). Mother’s child was a per se abused child given that at birth, a drug screen of the child revealed the presence of cocaine. Judgment affirmed. | Huffman | Montgomery |
1/16/2026
|
1/16/2026
| 2026-Ohio-142 |
|
State v. Smith
| 30538 | On remand, the trial court correctly advised appellant of his presumed duty to enroll in the violent offender database and his right to file a motion to rebut the presumption. The trial court did not err when it overruled appellant’s motion to rebut the presumed duty to enroll in the violent offender database. Because appellant’s convictions were affirmed on his first appeal, the trial court was without jurisdiction to consider appellant’s motions requesting vacation of his guilty plea. Appellant’s cumulative error argument is without merit. Finally, the trial court did not resentence appellant. Judgment affirmed. | Tucker | Montgomery |
1/16/2026
|
1/16/2026
| 2026-Ohio-144 |
|
State v. Murphy
| 2024-CA-20 | The trial court did not err in denying appellant’s motion to suppress the drugs found in her vehicle following an alert by a drug-detecting dog. The testimony of the K-9 handler established that the dog was trained and certified in the detection of methamphetamine prior to the traffic stop. Appellant’s conviction for aggravated possession of drugs (methamphetamine) was based on sufficient evidence and was not against the manifest weight of the evidence. Judgment affirmed. | Epley | Darke |
1/16/2026
|
1/16/2026
| 2026-Ohio-143 |
|
State v. Wa Tenza
| 2025-CA-7 | Appellant’s conviction for assault, a first-degree misdemeanor, was not against the manifest weight of the evidence. Although appellant produced evidence that he acted in self-defense, the jury reasonably credited the State’s evidence disproving the self-defense claim. Judgment affirmed. | Hanseman | Greene |
1/16/2026
|
1/16/2026
| 2026-Ohio-145 |
|
State v. Clutter
| 2025-CA-14 | The trial court did not err in imposing a 12-month prison sentence upon revoking community control because appellant’s violations were not “technical violations,” as provided by R.C. 2929.15(E). The trial court was not required to abide by the parties’ joint sentencing recommendation in sentencing appellant. Judgment affirmed. | Lewis | Champaign |
1/16/2026
|
1/16/2026
| 2026-Ohio-139 |
|
State v. Brandon
| 2025-CA-38 | The trial court did not abuse its discretion in overruling appellant’s presentence motion to withdraw his guilty plea. Judgment affirmed. | Tucker | Clark |
1/9/2026
|
1/9/2026
| 2026-Ohio-48 |
|
State v. Sweeney
| 2023-CA-58 | In this reopened appeal, the trial court committed plain error by admitting the laboratory report identifying the controlled substance allegedly possessed by appellant because the procedural requirements of R.C. 2925.51 to admit the report had not been satisfied. Appellant’s claim regarding the sufficiency of the evidence lacks merit because all evidence admitted at trial, including improperly admitted evidence, must be considered in reviewing such a claim. Based on the resolution of appellant’s claim regarding the lab report, his claim regarding the ineffective assistance of trial counsel is moot. The inadmissible lab report was essential to appellant’s aggravated possession of drugs conviction, so prior appellate counsel rendered ineffective assistance in failing to challenge the report on appellant’s direct appeal. Prior appellate judgment vacated. Trial court judgment reversed and remanded. (Huffman, J., dissenting.) | Hanseman | Clark |
1/9/2026
|
1/9/2026
| 2026-Ohio-57 |
|
State v. Harrell
| 2024-CA-62 | Appellant’s conviction for engaging in a pattern of corrupt activity is supported by sufficient evidence. Appellant was not prejudiced by the State’s amendment to the indictment. Judgment affirmed. | Lewis | Clark |
1/9/2026
|
1/9/2026
| 2026-Ohio-54 |
|
State v. Uchyn
| 2025-CA-4 | By failing to renew his Crim.R. 29 motion at the close of evidence, appellant waived his argument that his conviction for murder of the female victim is not supported by sufficient evidence. Even considering the merits, sufficient evidence supports appellant’s murder conviction. Appellant’s conviction for murder of the male victim is supported by sufficient evidence and is not against the manifest weight of the evidence. Judgment affirmed. | Huffman | Darke |
1/9/2026
|
1/9/2026
| 2026-Ohio-58 |
|
State v. Hanson
| 2025-CA-17 | Appellant’s sentence was not contrary to law because it was within the statutory range, and the trial court considered the purposes and principles of felony sentencing in R.C. 2929.11 and the seriousness and recidivism factors of R.C. 2929.12. Judgment affirmed. | Epley | Champaign |
1/9/2026
|
1/9/2026
| 2026-Ohio-53 |
|
State v. Davis
| 2025-CA-23 | Appellant has not shown ineffective assistance of counsel based on his trial attorney’s stipulation to the admissibility of a competency examination report and failure to request a second opinion. Appellant’s sentence of 30 years to life in prison is not subject to vacation or modification under R.C. 2953.08(G)(2). Judgment affirmed. | Tucker | Miami |
1/9/2026
|
1/9/2026
| 2026-Ohio-52 |
|
Capital One, N.A. v. Campbell
| 30577 | The trial court did not err in granting summary judgment to appellee and in dismissing appellant’s counterclaim. Appellee provided appropriate and authenticated information to substantiate its claim for recovery on appellant’s unpaid credit card account. Appellant failed to respond to appellee’s summary judgment motion and failed to submit any proper Civ.R. 56 materials. Under a plain error analysis, no error or plain error occurred. Appellant’s asserted defenses to the complaint and his counterclaim were also purely frivolous. Judgment affirmed. | Hanseman | Montgomery |
1/2/2026
|
1/2/2026
| 2026-Ohio-1 |
|
State v. Eichenlaub
| 30455 | The trial court properly overruled the appellant’s motion to suppress statements that were not the product of a custodial interrogation. The trial court did not err in refusing to order separate trials where the evidence supporting two separate indictments was simple and distinct. The appellant’s convictions are supported by legally sufficient evidence and are not against the manifest weight of the evidence. Judgment affirmed. | Tucker | Montgomery |
1/2/2026
|
1/2/2026
| 2026-Ohio-2 |
|
In re J.H.
| 30528, 30529, 30530, 30531, 30532 | Juvenile court did not abuse its discretion or violate mother’s right to due process by denying her oral motion for a continuance to allow her to attend the permanent custody hearing virtually from prison. Judgment affirmed. | Epley | Montgomery |
1/2/2026
|
1/2/2026
| 2026-Ohio-4 |
|
Jones v. Jones
| 30508 | On remand, the trial court correctly decided that appellee owed appellant interest on $1,770.46, with this amount being the difference between the marital assets awarded appellant and appellee. This result was equitable and compliant with R.C. 1343.03(A). Judgment affirmed. | Tucker | Montgomery |
1/2/2026
|
1/2/2026
| 2026-Ohio-5 |
|
State v. Latham
| 2025-CA-9 | The trial court did not err in failing to impose the sentence the parties jointly recommended in their plea agreement. The court informed appellant that it was not bound by the agreement and informed appellant of the possible range of sentences he could receive. In addition, the sentence is not contrary to law. Judgment affirmed. | Hanseman | Champaign |
1/2/2026
|
1/2/2026
| 2026-Ohio-6 |
|
State v. Holden
| 2025-CA-27 | Appellant’s sentence is not contrary to law because it is within the statutory range, and the trial court considered the purposes and principles of felony sentencing in R.C. 2929.11 and the seriousness and recidivism factors of R.C. 2929.12. Judgment affirmed. | Epley | Miami |
1/2/2026
|
1/2/2026
| 2026-Ohio-3 |