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In re T.B.
| C-250279, C-250288 | FOURTH AMENDMENT — OHIO CONST., ART. I, § 14 — TERRY — REASONABLE SUSPICION — JAYWALKING — R.C. 2935.26(A) — AUTOMATIC-COMPANION RULE — EVID.R. 901(A) — AUTHENTICATION — CHAIN OF CUSTODY — SUFFICIENCY — MANIFEST WEIGHT — CARRYING CONCEALED WEAPONS — MOTION TO WITHDRAW A PLEA: The juvenile court did not err in denying juvenile’s motion to suppress the gun found on his person as the fruit of an unreasonable seizure because an officer had observed the juvenile crossing the street illegally and was therefore authorized to perform a limited detention for the purpose of citing juvenile, as contemplated by R.C. 2935.26(A). The juvenile court did not err in denying juvenile’s motion to suppress the gun found on his person as the fruit of an unreasonable search because the officer who stopped juvenile reasonably suspected that juvenile was armed and dangerous based on (1) another officer’s report that juvenile and his companion had bulges consistent with firearms in their waistband areas, and (2) the officer’s own frisk of the companion, which revealed a firearm, thereby corroborating the other officer’s report. The juvenile court did not err in denying juvenile’s motion to exclude the firearm found on his person under Evid.R. 901(A) where body-worn-camera footage and officer testimony provided a rough chain of custody stretching back to the moment the gun was removed from juvenile’s person. Sufficient evidence supported the juvenile court’s finding that the firearm taken from juvenile’s person was operable, and that finding was not against the manifest weight of the evidence. The juvenile court abused its discretion by implicitly denying juvenile’s motion to withdraw his plea of “admit” to the jaywalking charge, where (1) juvenile was presumptively entitled to withdraw his plea because he had made his motion prior to any final order of disposition, (2) the juvenile court had granted juvenile’s contemporaneous motion to withdraw his plea to the concealed-carry charge, and (3) the juvenile court offered no explanation for why the motion to withdraw the plea to the jaywalking charge should be denied or why it should be treated differently than the motion in the concealed-carry case. | Crouse | Hamilton |
4/10/2026
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4/10/2026
| 2026-Ohio-1309 |
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In re J.D.
| C-250372 | INVOLUNTARY COMMITMENT — PROBATE COURT — EXPUNGEMENT — LAW OF THE CASE: The probate court properly denied appellant’s motion to expunge the records of his involuntary commitment because the involuntary-commitment statute does not authorize the expungement of appellant’s involuntary-commitment records and the court of appeals has already determined that the probate court lacked inherent authority to expunge those records. | Bock | Hamilton |
4/10/2026
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4/10/2026
| 2026-Ohio-1310 |
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State v. Smith
| C-250216 | EVIDENCE — SUFFICIENCY — MANIFEST WEIGHT — DISORDERLY CONDUCT — RECKLESSNESS: Defendant’s conviction for disorderly conduct was supported by sufficient evidence where the victim testified that defendant continued to broadcast the victim on social media at a bar after the victim asked defendant to get away and hit defendant’s phone out of her hand, blocked the victim’s mother’s driveway with her car at 2:00 a.m. and refused to move her car, broadcast the victim and the victim’s mother’s house on social media, and approached the victim’s mother after fighting the victim in front of the house. | Bock | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1262 |
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State v. McCrary
| C-250240 | WAIVER — RIGHT TO COUNSEL — SELF-REPRESENTATION — CRIM.R. 44 — SUFFICIENCY – MOTION TO SUPPRESS – PROBABLE CAUSE – DRUG OFFENSES: The trial court erred by failing to perform the necessary colloquy under Crim.R. 44(A) to determine whether defendant knowingly, intelligently, and voluntarily waived his right to counsel, where defendant was not apprised of the role of defense counsel, the nature of the charges and the statutory offenses included within them, the range of potential punishments, the possible defenses and mitigating circumstances, and all other essential facts that provide a comprehensive understanding of the whole matter. Defendant’s convictions for trafficking and possession of a controlled substance were supported by sufficient evidence where the State presented evidence demonstrating that defendant both actually and constructively possessed and trafficked in the controlled substances. The trial court did not err in denying defendant’s motion to suppress where an officer observed defendant conduct multiple hand-to-hand drug transactions, supplying probable cause for his arrest. | Kinsley | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1263 |
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State v. Boddy
| C-250250 | NO-CONTEST PLEAS — CRIM.R. 11(C)(2)(B) — MOTION TO DISMISS — SECOND AMENDMENT —WITHDRAWAL: The trial court did not err by accepting defendant’s no-contest pleas where defendant expressly tendered his no-contest pleas in a writing, changing his pleas from not guilty to no contest, and did not orally tender his no-contest pleas. Although the trial court did not fully comply with Crim.R. 11(C)(2)(b)’s requirement to inform defendant of the effect of his no-contest pleas, the court did not completely fail to comply, requiring defendant to establish prejudice, and defendant failed to allege or demonstrate that he would not have entered the pleas, but for the court’s failure to explain the effect of the pleas. Defendant withdrew or abandoned his motion to dismiss the charges for violating his Second Amendment right to bear arms by failing to argue it below, and by withdrawing the motion, defendant waived the issue for appeal. | Zayas | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1264 |
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State v. Jones
| C-250269, C-250270 | EVIDENCE — SUFFICIENCY — PERMITTING DRUG ABUSE — CHILD ENDANGERMENT — CUSTODY OR CONTROL: Defendant’s conviction for permitting drug abuse was supported by sufficient evidence where the State presented evidence that officers located drug scales, baggies, large amounts of cash, firearms, and a small quantity of drugs in defendant’s home. Defendant’s convictions for child endangerment under Cincinnati Mun.Code 915-3(a) following an officer’s locating accessible firearms in defendant’s home in which she cohabitated with her boyfriend and her boyfriend’s minor children were based on insufficient evidence where the State failed to present any evidence that defendant had custody or control over her boyfriend’s children or was in loco parentis to the children. | Bock | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1265 |
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Asbury Woods Senior Apts. v. Render
| C-250297, C-250298 | MOTION FOR RECONSIDERATION — HANDWRITING — AUTHENTICATION: The trial court did not err when it failed to rule on defendant’s motion for reconsideration of its judgment overruling defendant’s objections to the magistrate’s decision because a motion for reconsideration of a final judgment is a nullity. The magistrate did not abuse his discretion when he admitted a form transferring responsibility over utility payments to defendant into the evidence despite defendant’s claim that her signature on the form was forged because the magistrate was allowed to compare the allegedly forged signature with defendant’s signature on other documents in the record and could have concluded that allegedly forged signature was defendant’s. The magistrate did not err when he allowed plaintiff-landlord’s damages claim to continue after plaintiff-landlord’s eviction claim was dismissed because there is no indication that defendant-tenant requested a dismissal of the damages claim and because the damages claim was separate from, and independent of, the eviction claim. | Bock | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1266 |
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State v. Unser
| C-250329 | MOTION TO SUPPRESS — FOURTH AMENDMENT — LAWFUL SEARCH — VEHICLE — FREE AIR SNIFF — EXPLANATION OF THE CIRCUMSTANCES — POSSESSING DRUG ABUSE INSTRUMENTS: Defendant’s motion to suppress was properly denied where the responding police officer did not prolong a traffic stop to perform a free air sniff with his dog and where the dog provided the officer with probable cause to perform a legal search of the defendant’s vehicle. Where defendant pleaded no contest to possessing drug abuse instruments, the trial court did not err in convicting defendant of a misdemeanor of the first degree because the State’s recitation of the facts is not part of the State’s burden of proof and the trial court had adequate knowledge of the defendant’s prior drug charges. | Nestor | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1267 |
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In re B.B.
| C-250428 | R.C. 3109.04(E) — R.C. 2151.42 — LEGAL CUSTODY — CHANGED CIRCUMSTANCES: The juvenile court was mistaken when it applied R.C. 3109.04(E)(1)(a), rather than R.C. 2151.42(B), to assess mother’s request to modify the juvenile court’s prior dispositional order, which had awarded legal custody to father pursuant to R.C. 2151.353(A)(3). The juvenile court reasonably found that mother had failed to prove that changes in circumstances required a modification of its prior dispositional order awarding custody to father. Although the juvenile court applied the wrong statutory standard, its judgment was affirmed, because the standard it should have applied under R.C. 2151.42(B) was more onerous than the standard that trial court found mother had failed to meet under R.C. 3109.04(E)(1)(a)(iii). | Crouse | Hamilton |
4/8/2026
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4/8/2026
| 2026-Ohio-1268 |
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In re J.L.
| C-250036 | JUVENILE — CUSTODY — NONPARENT — MOOTNESS — EVIDENCE — ABANDONMENT — CIV.R. 60(B) — JUV.R. 13 — R.C. 2151.23(A)(2): A judgment granting legal custody to a nonparent under R.C. 2151.23(A)(2) supersedes an interim-custody order entered under Juv.R. 13(A) and renders any subsequent challenge to the interim-custody order moot. An interim-custody order entered under Juv.R. 13(A) does not bar subsequent litigation of a parent’s suitability. The juvenile court did not abuse its discretion in awarding legal custody of father’s daughter to appellee grandmother where the record supports that father abandoned his daughter by having no contact with her for at least an eight-year period because he wanted to avoid confrontation with mother. The juvenile court did not abuse its discretion when denying father’s motion for relief from the legal-custody judgment under Civ.R. 60(B) without holding a hearing where father failed to allege operative facts warranting relief. | Zayas | Hamilton |
4/3/2026
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4/3/2026
| 2026-Ohio-1216 |
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State v. Whitney
| C-250349 | COMMUNITY CONTROL – NOTICE – PREJUDICE – R.C. 2929.19: Where the trial court failed to provide all statutory warnings under R.C. 2929.19 when imposing a term of community control, and where defendant did not appeal the trial court’s initial imposition of community control, when defendant later violated the terms of community control the trial court did not err in sentencing defendant to a sanction it had informed defendant of because defendant suffered no prejudice from the trial court’s failure to provide the rest of the warnings. | Nestor | Hamilton |
4/3/2026
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4/3/2026
| 2026-Ohio-1217 |
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Kuchera v. Pfalzgraf
| C-250453 | R.C. 3109.04 — PARENTING TIME — BEST INTEREST — OBJECTIONS — CONTEMPT — ATTORNEY FEES — GUARDIAN AD LITEM FEES: The trial court did not abuse its discretion in granting father’s motion to modify parenting time where the record established that the modification was in the best interest of the child. The trial court did not abuse its discretion in failing to find father in contempt of court for multiple violations of a shared-parenting plan and court orders where the record supported the trial court’s determinations that father did not withhold parenting time from mother, block mother from contacting the child, fail to provide mother with login information for the child’s devices, or fail to set up a court-ordered wage-deduction order, and that father’s unilateral decision making regarding the child’s care did not rise to the level of contempt. The trial court did not abuse its discretion in failing to award mother all requested attorney fees where father prevailed on the motion to modify parenting time and on all but one of the alleged violations in mother’s motion for contempt. The trial court did not abuse its discretion in ordering each parent to pay half of the guardian ad litem’s outstanding fees. | Crouse | Hamilton |
4/3/2026
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4/3/2026
| 2026-Ohio-1218 |
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State v. Wilson
| C-240696 | HEARSAY – PLAIN ERROR – EVID.R. 803(4) – HARMLESS ERROR – COUNSEL – INEFFECTIVE ASSISTANCE – CUMULATIVE ERROR – BRADY – MANIFEST WEIGHT OF THE EVIDENCE – SENTENCING – CONSECUTIVE SENTENCES: The trial court did not err by allowing multiple hearsay statements into evidence where defendant did not object and did not raise plain error on appeal. The trial court erred in admitting a hearsay statement on the basis that the statement was admissible for its effect on the listener where the declarant took no action, but the error was harmless. The trial court did not err in admitting witness testimony offered to explain the investigation because it was nonhearsay, where the testimony was relevant, the testimony was more probative than prejudicial, and the testimony did not connect the defendant to the crime. The trial court did not commit plain error by admitting statements made to a social worker for the purposes of medical diagnosis and treatment because they were admissible under Evid.R. 803(4). The trial court erred in admitting the therapist’s testimony to bolster the victim’s credibility, but the error was harmless where the victim testified, allowing the jury to ascertain the victim’s credibility. Defense counsel was not ineffective for failing to challenge the therapist’s testimony and the Mayerson Center report because the evidence was admissible under Evid.R. 803(4). Counsel was not ineffective for failing to object to the State’s written timeline and agreeing to admit the transcript of the Mayerson Center interview where both exhibits were demonstrative in nature to aid the jury, the timeline mirrored the indictment, the defendant did not allege any difference between the video and the transcript, and the defendant did not establish that he was prejudiced by the evidence. Counsel was not ineffective for failing to object to the victim’s testimony that attending court proceedings was a financial burden where defense counsel used the testimony to undermine the victim’s credibility. Defendant failed to demonstrate that cumulative errors denied him of due process and a fair trial where he failed to establish a reasonable probability the outcome would have been different after viewing the harmless errors cumulatively. The State did not fail to disclose exculpatory evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), where the evidence was disclosed during the trial, the evidence was not material to guilt or punishment, and the evidence related to an unsuccessful investigative attempt. Defendant’s convictions were not against the manifest weight of the evidence where the factfinder believed the victim’s testimony. The trial court erred in imposing consecutive sentences where the court failed to make the requisite findings under R.C. 2919.14 (C)(4) prior to imposing consecutive sentences. | Zayas | Hamilton |
4/1/2026
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4/1/2026
| 2026-Ohio-1178 |
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Rialto on Hurstbourne, L.L.C. v. US LBM Operating Co. 3009, L.L.C.
| C-250077 | SUMMARY JUDGMENT — CIV.R. 56 — OHIO PRODUCTS LIABILITY ACT — ECONOMIC HARM — BREACH OF CONTRACT — BREACH OF WARRANTY — EXPRESS WARRANTIES — WARRANTY OF MERCHANTABILITY — WARRANTY OF FITNESS — DESIGN DEFECTS — INDEMNITY — ATTORNEY FEES: Because plaintiff-buyer alleged only economic harm in the form of nonphysical property damage, losses in value, cost of replacement, and consequential business harms, its breach-of-warranty claims were not governed by the Ohio Products Liability Act, codified at R.C. 2307.71 through 2307.80.The trial court’s summary judgment for defendant-seller on plaintiff-buyer’s claims for breach of express warranties of merchantability and suitability for intended purpose was improper where plaintiff-buyer’s expert evidence showed that flooring materials delivered by defendant-seller failed to provide noise isolation that came close to the manufacturer’s advertised capabilities and fell below generally-accepted housing-code standards, because a reasonable factfinder could determine that the flooring material had failed to conform to the warranties. The trial court’s summary judgment for defendant-seller on plaintiff-buyer’s claim for breach of an express warranty against defects in design was proper where context indicated that the design-defect warranty covered only defects that rendered the product unsafe, and where plaintiff-buyer had not alleged that the flooring material at issue was not reasonably safe. Defendant-seller was not entitled to summary judgment on plaintiff-buyer’s breach-of-warranty claims where plaintiff-buyer had introduced evidence that would support a plausible theory of damages, even if plaintiff-buyer did not adequately prove what those damages would be. Plaintiff-buyer would not be entitled to recover attorney fees from defendant-seller under the contract’s indemnification provision, in which defendant-seller promised to indemnify plaintiff-buyer for litigation expenses resulting from a breach of warranty, because it was ambiguous whether the parties intended the indemnification provision to permit recovery of litigation expenses incurred in direct actions between the contracting parties, and ambiguous provisions are to be construed against the party that drafted them—in this case, plaintiff-buyer. | Crouse | Hamilton |
4/1/2026
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4/1/2026
| 2026-Ohio-1179 |
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State v. Flannery
| C-250230 | GRAND JURY — TESTIMONY — CRIM.R. 6(E) — DISCLOSURE: Where defendant had a particularized need to establish whether exculpatory evidence was presented to the grand jury, and where the State stipulated it had not presented any exculpatory evidence to that body, defendant’s particularized need was met and the trial court abused its discretion in ordering disclosure of additional testimony from the grand jury transcript. | Crouse | Hamilton |
3/27/2026
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3/27/2026
| 2026-Ohio-1076 |
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In re S.H.
| C-250361 | JUVENILE — DELINQUENCY — VENUE — CIRCUMSTANTIAL EVIDENCE — SUFFICIENCY — MANIFEST WEIGHT: The State presented sufficient circumstantial evidence to establish venue where the testimony of the officer includes mention of two responding police departments, several road names that are all in the same area and connect in some manner, several landmarks, and descriptions of the area that all identify the area in which this incident occurred as Indian Hill, a State’s exhibit identifies the area of the accident on Given Road, which was at Livingston Lodge, as being located in “Cincinnati, Ohio,” the police report attached to the complaint is from the Indian Hill Rangers, the complaint was file stamped in Hamilton County, and the police report was assigned a Hamilton County case number. | Zayas | Hamilton |
3/27/2026
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3/27/2026
| 2026-Ohio-1077 |
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LVNV Funding, L.L.C. v. Evans
| C-250383 | SUMMARY JUDGMENT — CIVIL PLAIN ERROR: Where defendant-debtor failed to file objections to the magistrate’s decision granting summary judgment in favor of plaintiff-creditor, defendant-debtor waived all but plain error on appeal, and the trial court’s judgment adopting the magistrate’s decision and granting summary judgment in favor of the plaintiff-creditor will be affirmed where defendant-debtor failed to raise a plain-error argument on appeal and plain error is not apparent in the record or the trial court’s decision. | Zayas | Hamilton |
3/27/2026
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3/27/2026
| 2026-Ohio-1078 |
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State v. Held
| C-250268 | OVI — CHEMICAL TEST — REFUSAL — R.C. 4511.19(A)(2) — MOTION TO SUPPRESS — SUFFICIENCY — MANIFEST WEIGHT: In an OVI prosecution, the trial court did not err in denying a motion to dismiss where officer observation that defendant smelled strongly of alcohol, had bloodshot and watery eyes, slurred his speech, was acting strangely, and refused to participate in field sobriety tests supported a finding of probable cause to arrest for OVI. Defendant’s conviction for refusing to take a chemical test under R.C. 4511.19(A)(2) was supported by sufficient evidence and was not against the manifest weight of the evidence where the jury considered testimony from the arresting officers that defendant strongly smelled of alcohol, had bloodshot and watery eyes, slurred his speech, acted strangely, and refused to participate in field sobriety testing, and could observe footage from an officer’s body-worn camera showing defendant’s actions. | Moore | Hamilton |
3/18/2026
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3/18/2026
| 2026-Ohio-898 |
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GEICO Ins. Co. v. Glendale Body Shop, Inc.
| C-250278 | R.C. 4513.70 — STORAGE FACILITY — TOWING SERVICE — FOR-HIRE MOTOR CARRIER — REASONABLE CHARGES — EVIDENCE: Defendant car repair shop is not a “towing service” under R.C. 4513.70 where the shop was hired to facilitate having the insured’s car towed by a third-party towing company but did not itself carry or transport the insured’s car. Defendant car repair shop is a “storage facility” under R.C. 4513.70 where nothing in R.C. 4513.70 prevents the shop from functioning as both a “storage facility” and a “repair facility” under R.C. Ch. 4513 and where the evidence shows that the shop charged storage fees from the first day that the insured’s vehicle arrived at the shop, included storage fees as a part of the repair costs in the contract for repairs, and accepted vehicles that were “an obvious total loss” from plaintiff insurer on other claims. The trial court did not abuse its discretion in determining that storage charges for ten days was reasonable under the circumstances where the testimony established that storage is typically not charged until there is a total-loss determination and plaintiff insurer presented evidence that the ten days of storage arises from the date the insured’s vehicle was determined to be a total loss with a “few extra days” covered in the beginning. | Zayas | Hamilton |
3/18/2026
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3/18/2026
| 2026-Ohio-899 |
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State v. Hurt
| C-250236 | CRIM.R. 33(B) — UNAVOIDABLY PREVENTED — NEWLY DISCOVERED EVIDENCE: Although the trial court, when ruling on defendant’s Crim.R. 33(B) motion for leave to file a new-trial motion, improperly considered the merits of defendant’s new-trial motion and whether defendant had delayed seeking leave after discovering the new evidence on which his new-trial motion was based, this did not result in prejudicial error nor did the trial court abuse its discretion in denying the motion for leave where the court also conducted the proper inquiry and determined that defendant was not unavoidably prevented from discovering his codefendant’s confession within 120-days of the jury’s verdict. | Bock | Hamilton |
3/13/2026
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3/13/2026
| 2026-Ohio-851 |
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State v. Jones
| C-250308 | IRRECONCILABLE CONFLICT – OBSTRUCTING OFFICIAL BUSINESS – PLAIN ERROR – RESISTING ARREST – R.C. 1.51 – R.C. 2921.31 – R.C. 2921.33: The trial court did not commit plain error in convicting defendant of obstructing official business under R.C. 2921.31, because R.C. 2921.31 is not in irreconcilable conflict with R.C. 2921.33, the resisting arrest statute, and the State had discretion in determining under which statute to charge defendant. | Nestor | Hamilton |
3/13/2026
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3/13/2026
| 2026-Ohio-852 |
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Ohnstad v. Bruce & Mary Ann Erickson Found.
| C-240714, C-250239 | SUMMARY JUDGMENT — SUFFICIENCY OF SERVICE OF PROCESS — STATUTE OF LIMITATIONS — COMMENCEMENT — CAPACITY — WAIVER — TRUST: Defendant trust waived the defense of lack of capacity to be sued by not asserting the defense in its answer and the trial court accordingly erred in granting the trust summary judgment on plaintiffs’ claims based on plaintiffs’ failure to perfect service where plaintiffs served the trustee of the trust within the statute-of-limitations period and plaintiffs’ naming the trust rather than the trustee as the defendant did not cause service to be insufficient because the trust waived the defense of lack of capacity. Plaintiffs’ challenge to the trial court’s denial of their motion for relief from judgment was moot where the appellate court reversed the trial court’s summary judgment from which plaintiffs sought relief. | Bock | Hamilton |
3/11/2026
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3/11/2026
| 2026-Ohio-810 |
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State v. Barrow
| C-250259 | MOTION TO DISMISS — CHILD ENDANGERMENT — CINCINNATI MUN.CODE 915-3 — R.C. 9.68 — FIREARM: The trial court erred in granting defendant’s motions to dismiss three charges of child endangerment in violation of Cincinnati Mun.Code 915-3 where the dismissals were based on the trial court’s erroneous determination that that this provision was preempted by R.C. 9.68. Following this court’s opinion in State v. West, 2024-Ohio-1951 (1st Dist.), the State may continue to charge offenders under Cincinnati Mun.Code 915-3, and where the charges relate to the offender’s storage of firearms, the trier of fact must decide, based on the individual facts of each case, whether the offender’s storage of the firearm created a substantial risk to the health or safety of the child. [But see DISSENT: The trial court did not err in dismissing the complaints where the complaints charged a violation of Cincinnati Mun.Code 915-3(b), which was nullified in State v. West, 2024-Ohio-1951 (1st Dist.), because it redefined the element of substantial risk to include the negligent storage of firearms.] | Crouse | Hamilton |
3/11/2026
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3/11/2026
| 2026-Ohio-811 |
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State v. Thompkins
| C-250277 | ABUSE OF DISCRETION – R.C. 2929.28 – RESTITUTION: The trial court did not abuse its discretion in ordering defendant to pay $6,341.43 in restitution after a two-day restitution hearing because the testimony and evidence presented by the State supported the award, and the trial court’s decision to deduct some charges, and not others, was within the trial court’s discretion. | Nestor | Hamilton |
3/11/2026
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3/11/2026
| 2026-Ohio-812 |
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Walker v. JPMorgan Chase Bank, N.A.
| C-250451 | MOTION TO DISMISS — CREDIT-CARD APPLICATION — IMPLIED-IN-FACT CONTRACT — UNJUST ENRICHMENT — CONSTRUCTIVE FRAUD — BREACH OF FIDUCIARY DUTY — DECLARATORY JUDGMENT: Plaintiff’s breach-of-implied-contract claim based on defendant bank’s retention of plaintiff’s personal information included in a denied credit-card application was properly dismissed where the processing of a credit-card application does not form a contract and plaintiff pleaded no facts supporting an inference that the bank agreed to enter into contract with plaintiff. Plaintiff’s unjust-enrichment claim was properly dismissed where plaintiff alleged no facts supporting an inference that she conferred a benefit on defendant through the submission of a credit-card application that included her personal information and did not allege that her information had monetary value or that the bank sold the information for a profit. Plaintiff’s conversion claim was properly dismissed where her complaint alleged that defendant came into possession of her property lawfully and did not allege that plaintiff demanded the return of the property and defendant refused to return the property. Plaintiff’s breach-of-fiduciary-duty claim was properly dismissed where plaintiff’s submission of a credit-card application to defendant bank did not establish a fiduciary relationship between the two. Plaintiff’s constructive-fraud claim was properly dismissed where defendant bank owed no duty to disclose facts to plaintiff as it did not stand in any special relationship that would result in defendant owing plaintiff a duty to disclose. Plaintiff’s challenge to the trial court’s dismissal of her declaratory-judgment claim is overruled where plaintiff failed to comply with App.R. 16 by not citing to any relevant law. | Bock | Hamilton |
3/11/2026
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3/11/2026
| 2026-Ohio-813 |
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State v. Gray
| C-250459 | CRIMINAL DAMAGING — WITHOUT CONSENT — CIRCUMSTANTIAL EVIDENCE — CLERICAL ERROR — RESTITUTION: Defendant’s conviction for criminal damaging was supported by sufficient evidence because a rational trier of fact could infer that defendant damaged the victim’s property without the victim’s consent based on tension preceding the damaging, the victim involving the police in the dispute, and the victim’s pursuit of repair estimates. Defendant’s conviction for criminal damaging was not contrary to the weight of the evidence because the trier of fact was entitled to find the victim’s testimony credible despite minor inconsistencies in the victim’s account. The trial court did not commit plain error when it relied on excluded testimony and information from the State to determine restitution because evidentiary rules are inapplicable at sentencing proceedings and the restitution statute allows the trial court to consider information provided by the State. | Bock | Hamilton |
3/11/2026
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3/11/2026
| 2026-Ohio-814 |
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In re S.P.
| C-250641 | PARENTAL TERMINATION — PERMANENT CUSTODY — EVIDENCE — MANIFEST WEIGHT — BEST INTEREST OF THE CHILD — LEGALLY SECURE PLACEMENT — ABANDONMENT: Where Mother failed to assert in her objection to the magistrate’s decision that the magistrate’s decision was not supported by sufficient evidence, and she did not advance a plain-error argument on appeal, she has failed to preserve this argument for appeal. The juvenile court’s decision to commit the children to the permanent custody of the Hamilton County Department of Job and Family Services was not contrary to the manifest weight of the evidence where the evidence demonstrated that permanent custody was in the children’s best interest where the record and testimony showed that the children had been in the agency’s care for approximately 16 consecutive months, and Mother (1) failed to visit the children for nearly three years, (2) refused to sign a release of information so that she could be referred for services, including making a referral so that Mother could continue supervised visits, (3) failed to remedy the concerns regarding her housing, including having working utilities, and (4) failed to verify her income. The juvenile court’s finding that the children could not be placed with Mother within a reasonable time or should not be placed with Mother was not contrary to the manifest weight of the evidence where the evidence demonstrated that she did not remedy the issues that initially caused the children to be removed from her care. | Moore | Hamilton |
3/11/2026
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3/11/2026
| 2026-Ohio-815 |
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State v. Giron
| C-250342, C-250343 | MOTION TO SUPPRESS — OPERATING A MOTOR VEHICLE WHILE INTOXICATED — PROBABLE CAUSE — REASONABLE SUSPICION — CRIM.R. 7(D) — AMENDMENT OF CHARGE: The trial court did not abuse its discretion in permitting the State to amend the statutory subsection that formed the basis of its operating a motor vehicle while under the influence charge from R.C. 4511.19(A)(1)(a) to R.C. 4511.19(A)(1)(d) as the amendment did not change the name or identity of the crime, nor did it prejudice defendant. The trial court did not err in denying defendant’s motion to suppress, as reasonable suspicion supported the officer’s traffic stop of defendant’s vehicle where the license plate inquiry indicated that the car was not registered to a licensed driver, and the officer had probable cause to arrest defendant for operating a motor vehicle while under the influence where defendant smelled of alcohol, had bloodshot eyes and slurred speech, and was swaying during his interactions with the officer. | Kinsley | Hamilton |
3/6/2026
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3/6/2026
| 2026-Ohio-753 |
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State v. Johnson
| C-250220 | SECOND AMENDMENT — MOTION TO DISMISS — WEAPON UNDER A DISABILITY — CONCEALED CARRY — IMPROPER HANDLING OF FIREARMS IN A MOTOR VEHICLE: The trial court did not err in denying defendant’s motion to dismiss firearm charges based on Second Amendment grounds where the trial court found that defendant was a currently dangerous former felon, and the Second Amendment permits the disarmament of dangerous individuals. | Zayas | Hamilton |
3/4/2026
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3/4/2026
| 2026-Ohio-727 |
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Harcourt v. Strassel Constr. Co.
| C-250145 | WORKERS’ COMPENSATION — AMENDING A CLAIM — FLOW THROUGH CONDITION — CREDIBILITY: The trial court did not err in finding that the plaintiff failed to meet his burden of proof to amend his previous workers’ compensation claim where defendant’s expert witness testified that plaintiff did not even have the alleged injury. | Nestor | Hamilton |
2/27/2026
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2/27/2026
| 2026-Ohio-675 |
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State v. Courtney
| C-250172 | HAVING WEAPONS UNDER A DISABILITY — SELF-DEFENSE ACTUAL POSSESSION — CIRCUMSTANTIAL EVIDENCE: Defendant’s conviction for having a weapon while under a disability was supported by sufficient evidence and not contrary to the manifest weight of the evidence where eyewitness testimony and statements to police describing defendant’s flight with “his” firearm after shooting the victim in self-defense, combined with the absence of anyone seeing the firearm at the scene before the shooting, created an inference that defendant possessed the firearm before using it in self-defense. | Bock | Hamilton |
2/27/2026
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2/27/2026
| 2026-Ohio-676 |
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Dove v. Cincinnati Metro. Hous. Auth.
| C-250296 | R.C. 2744.02 — POLITICAL-SUBDIVISION IMMUNITY — PHYSICAL DEFECT: The trial court did not err in denying defendant landlord political subdivision’s motion for summary judgment on the issue of immunity from a negligence claim where defendant approved plaintiff tenant’s accommodation request for a grab-bar in her shower due to plaintiff’s disability, and defendant’s failure to install a shower grab-bar constituted a physical defect in the property. | Moore | Hamilton |
2/27/2026
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2/27/2026
| 2026-Ohio-677 |
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Planned Parenthood SW Ohio Region v. Ohio Dept. of Health
| C-250163 | REPRODUCTIVE FREEDOM AMENDMENT – SENATE BILL 27 – ABORTION – SEVERANCE: The trial court did not err in granting a judgment on the pleadings in favor of abortion providers who challenged a state law requiring fetal tissue from procedural abortions to be disposed of by cremation or interment, because Article I, Section 22 of the Ohio Constitution—the Reproductive Freedom Amendment—applies to laws regulating conduct occurring after an abortion. The trial court did not err in determining that provisions in a state law which cross-reference and give meaning to the unconstitutional requirement that fetal tissue from procedural abortion be disposed of by cremation or interment could not be severed. The trial court erred in failing to sever portions of a state law that added the terms “zygote” and “blastocyte” to preexisting abortion regulations from its injunction barring enforcement of the requirement that fetal tissue from procedural abortions be disposed of by cremation or interment, and the trial court’s judgment is modified to sever those provisions from the permanent injunction issued by the trial court. | Kinsley | Hamilton |
2/25/2026
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2/25/2026
| 2026-Ohio-639 |
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State v. Kirkland
| C-250142 | MURDER — WEAPON UNDER A DISABILITY — SUFFICIENCY — MANIFEST WEIGHT — OTHER-ACTS EVIDENCE — PROSECUTORIAL MISCONDUCT — GRUESOME PHOTOS —CONSECUTIVE SENTENCES — DUE PROCESS — POSTRELEASE CONTROL: Defendant’s murder conviction was supported by the evidence and not contrary to the weight of the evidence where the State established defendant had an altercation with his stepfather, had a key to the home where his stepfather was murdered, had gunshot residue on his sweatshirt, had a gunshot wound on his hand, left a trail of blood from the body to the back porch, the blood trail ended at the woods, and a video depicted defendant running out of the woods after the murder. The weapon-while-under-a-disability conviction was supported by sufficient evidence and not contrary to the weight of the evidence where the State proved that the loaded firearm contained defendant’s DNA and was operable, and DNA evidence linked defendant to the bullet fired from the unrecovered murder weapon. Assuming that the witness’s testimony that defendant had threatened her was other-acts testimony, defendant failed to establish he was prejudiced where the testimony was minor, the court instructed the jury to disregard it, the prosecution did not mention it in closing, and the remaining evidence was sufficient to overcome any prejudice. The prosecutor did not commit misconduct by eliciting the testimony where the witness volunteered the testimony, and the prosecutor asserted he was not trying to elicit the testimony, immediately ceased the questioning, did not object to the curative instruction, or mention the evidence in closing, and defendant failed to demonstrate any prejudice. The trial court did not err in admitting two photos from the crime scene because the probative value of the photos outweighed any prejudice where the photos depicted the crime scene, were relevant to show the position of the body and the blood drops, and illustrated the testimony of the forensic biologist who conducted DNA testing of the blood drops. The record supported consecutive sentences where the trial court considered defendant’s criminal history, which included a firearm conviction and prior incarceration, the victim’s relatives’ statements, the harm to the community from the offenses, the seriousness of the offenses, and the necessity of protecting the public. Defendant was not deprived of due process at the sentencing hearing where the court properly considered the principles and purposes of felony sentencing, the seriousness and recidivism factors, and the isolated religious reference did not affect the fundamental fairness of the sentencing. The trial court correctly informed defendant that postrelease control was not imposed on the murder conviction, but the cause must be remanded for the court to correct the sentencing entry nunc pro tunc to remove the imposition of postrelease control. | Zayas | Hamilton |
2/20/2026
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2/20/2026
| 2026-Ohio-586 |
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State v. Starr
| C-250221 | DISORDERLY CONDUCT — EVIDENCE — SUFFICIENCY: Defendant’s conviction for disorderly conduct was not supported by sufficient evidence where the State did not establish that defendant uttered fighting words likely to provoke a violent response by insulting a police officer or that the officer was annoyed, inconvenienced or alarmed by the insults. | Zayas | Hamilton |
2/20/2026
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2/20/2026
| 2026-Ohio-587 |
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State v. Hughes
| C-250021 | POSTCONVICTION — DNA TESTING — OUTCOME DETERMINATIVE — COMPLICITY — R.C. 2953.74: The court of appeals could not say the trial court erred by failing to consider defendant’s October application for postconviction DNA testing when ruling on his November application, because the October application was never made part of the record; because the trial court did not deny the November application as second, successive, or res judicata; and because the State was not arguing for affirmance on such a ground. The trial court did not abuse its discretion in holding that a result excluding defendant as a contributor of biological material deposited under the victim’s fingernails and on various items found on or around the victim’s body would not be outcome determinative under R.C. 2953.71(L) and R.C. 2953.74(C)(4) and (C)(5), where (1) defendant had been convicted on a complicity theory, (2) trial testimony did not clearly suggest defendant had touched the items at issue, (3) any unidentified DNA could plausibly have come from defendant’s accomplice or an innocuous contributor, (4) defendant had no other evidence corroborating the affidavit in which his accomplice averred that an alternative suspect was misidentified as defendant, (5) defendant’s original statement to police on which he originally relied was in tension with his alternative-suspect theory, and (6) four eyewitnesses familiar with the area and defendant’s face identified defendant as one of the assailants during his original trial. | Crouse | Hamilton |
2/18/2026
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2/18/2026
| 2026-Ohio-545 |
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In re L.D.
| C-250607 | R.C. 2151.414 – PARENTAL TERMINATION – BEST INTEREST: The juvenile court’s grant of permanent custody of Mother’s children to the Hamilton County Department of Job and Family Services was supported by sufficient evidence and was not contrary to the manifest weight of the evidence where the record showed Mother failed to manage her bipolar disorder and failed to remedy the cause that prompted the children’s removal. | Moore | Hamilton |
2/18/2026
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2/18/2026
| 2026-Ohio-546 |
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State v. Ngaide
| C-240635 | CONSTITUTIONAL LAW — SECOND AMENDMENT — GUNS — MOTION TO DISMISS — IMPROPERLY HANDLING FIREARMS IN A MOTOR VEHICLE — R.C. 2923.16 — QUALIFYING ADULTS — R.C. 2923.111 Where defendant was charged with improperly handling a firearm in a motor vehicle in violation of R.C. 2923.16(B), and where defendant had not been a qualifying adult at the time of the offense due to a pending violent-misdemeanor charge, the trial court did not err in denying defendant’s motion to dismiss on Second Amendment grounds under this court’s precedents upholding other improper-handling prosecutions, see State v. Stonewall, 2025-Ohio-4974 (1st Dist.); State v. Baxter, 2025-Ohio-5722 (1st Dist.), and upholding a concealed-carry conviction of an individual disqualified based on a pending violent-misdemeanor charge, see State v. Hall, 2025-Ohio-1644 (1st Dist.). [See CONCURRENCE by KINSLEY, P.J.: If Hall and subsequent precedents did not control this case, the constitutionality of the R.C. 2923.16(B) charge would be suspect for the reasons set forth in the dissent in Stonewall.] [See CONCURRENCE by CROUSE, J.: Because the State may prohibit carrying concealed weapons, and because the purpose, history, and most frequent application of R.C. 2923.16(B) demonstrate that it functions as a prohibition on concealing usable firearms in motor vehicles, the State may constitutionally apply R.C. 2923.16(B) to individuals who, like defendant, have weapons actually concealed from outside view within their motor vehicle, although the State may not be able to apply it to individuals whose weapons are not, in fact, concealed.] [But see DISSENT: The trial court should have granted defendant’s motion to dismiss because this court has not resolved whether R.C. 2923.16(B) is constitutional as applied to an individual disqualified because of a pending violent-misdemeanor charge, and because the application of R.C. 2923.16(B) to such an individual is inconsistent with this court’s holdings in State v. Brown, 2025-Ohio-8 (1st Dist.), and State v. Barber, 2025 Ohio-1193 (1st Dist.).] | Per Curiam | Hamilton |
2/13/2026
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2/13/2026
| 2026-Ohio-478 |
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Hilty v. Donnellon McCarthy Ents., Inc.
| C-240418 | DEFAMATION PER SE – TORTIOUS INTERFERENCE – BREACH OF SETTLEMENT AGREEMENT – QUALIFIED PRIVILEGE – ACTUAL MALICE – JURY INSTRUCTIONS – DERIVATIVE CLAIMS – NOTICE OF CROSS-APPEAL: Where plaintiff former employee sued his former employer for defamation, the trial court erred in finding that the former employer’s statements were protected under qualified privilege where the court improperly determined that the privilege applied based on the employer-employee relationship and did not fully consider the remaining elements of the qualified-privilege standard, and the court erred in instructing the jury that it had to find actual malice in order to find in favor of plaintiff on his defamation claim. The trial court erred in determining that plaintiff former employee’s breach-of-contract claim against his former employer was derivative of his defamation claim where the contract claim fell under a separate settlement contract between the parties. Where plaintiffs’ witness lacked firsthand knowledge of the statements about which he sought to testify, he lacked the personal knowledge required by Evid.R. 602. Where plaintiff could not definitively identify the caller, the trial court did not abuse its discretion in excluding evidence about a phone call. Where defendant-appellee failed to file a notice of cross-appeal but sought to assert a cross-assignment of error to change the trial court’s judgment, the cross-assignment of error must be dismissed. | Per Curiam | Hamilton |
2/11/2026
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2/11/2026
| 2026-Ohio-434 |
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State v. Higgins
| C-250149 | MOTION TO SUPPRESS — MIRANDA WARNINGS — CUSTODY—JURY WAIVER — BENCH TRIAL – JURISDICTION: The trial court properly denied defendant’s motion to suppress statements she made to a police officer when placed in a store’s loss-prevention room after being accused of theft where defendant was not in custody under Miranda v. Arizona, 384 U.S. 436 (1966), because defendant was not handcuffed or otherwise restrained, the door to the loss-prevention room was unlocked and open, and the officer made no threatening or coercive actions. The trial court lacked jurisdiction to hold a bench trial on defendant’s misdemeanor theft charge where defendant previously filed a jury demand and the trial court never obtained a written jury waiver from defendant. | Bock | Hamilton |
2/11/2026
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2/11/2026
| 2026-Ohio-435 |
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Ungerbuehler v. Kelly
| C-250201 | JUDGMENT ON THE PLEADINGS — CIV.R.12(C) — COMMON LAW WRONGFUL DISCHARGE — R.C. CH. 4112 — EMPLOYMENT DISCRIMINATION — WORKERS’ COMPENSATION RETALIATION — R.C. 4123.90: The trial court erred when it dismissed plaintiff-employee’s common-law wrongful-discharge claim in violation of Ohio’s public policy against employment discrimination on the basis of a person’s disability based on plaintiff-employee’s failure to allege facts that would satisfy the statutory definition of an employer because R.C. Ch. 4112’s definitional section does not inform the basis of the public policy announced in R.C. 4112.02(A). The trial court erred when it dismissed plaintiff-employee’s statutory claim for workers’ compensation retaliation under R.C. 4123.90 based on the “coming and going” rule because a workers’ compensation retaliation claim does not depend on a workplace injury or successful workers’ compensation claim. The trial court erred when it dismissed plaintiff-employee’s common-law wrongful-discharge claim in violation of Ohio’s public policy against workers’ compensation retaliation under R.C. 4123.90, because such claims are available to plaintiffs-employees who were terminated before they filed for workers’ compensation and regardless of whether their workers’ compensation claims would have been successful. | Bock | Hamilton |
2/11/2026
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2/11/2026
| 2026-Ohio-436 |
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Paeonian Ents., L.L.C. v. Fitworks Holding, L.L.C.
| C-250058 | COMMERCIAL LITIGATION — BREACH OF CONTRACT — BREACH OF LEASE — LANDLORD TENANT — SUMMARY JUDGMENT — DISCOVERY — ABUSE OF DISCRETION: The trial court did not err in granting summary judgment to a landlord leasing a commercial gym space where no genuine issues of material fact existed regarding the tenant’s breach of the lease by failing to pay rent for several months. The trial court did not abuse its discretion in granting the landlord’s request to reopen discovery for 90 days and in affording leave for the landlord to file dispositive motions despite the fact that the tenant’s motion for summary judgment was timely filed and already fully briefed. | Kinsley | Hamilton |
2/6/2026
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2/6/2026
| 2026-Ohio-379 |
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State v. Henderson
| C-250243 | PROCEDURE/CRIMINAL — CRIM.R. 47 — MOTION TO SUPPRESS — ABUSE OF DISCRETION — NOTICE — FOURTH AMENDMENT: Where defendant’s supplemental motion to suppress focused almost exclusively on the stop of a vehicle and did not allege that the search of that vehicle had been conducted without a warrant, and where the State’s bill of particulars had alleged that defendant had admitted to possessing contraband prior to the search, defendant’s supplemental motion to suppress failed to provide the State with adequate notice that defendant challenged the allegedly unconstitutional search and so did not adequately raise that issue under Crim.R. 47. Where defendant’s supplemental motion to suppress failed to provide the State with adequate prehearing notice of defendant’s challenge to the warrantless search, and where the State, in reliance on its understanding of the motion’s scope, offered no witnesses to testify about the search’s legality, and where the State was given no opportunity to call those necessary officers as witnesses after it learned that defendant sought to challenge the search, the trial court abused its discretion in granting defendant’s motion to suppress on the ground that the State had not met its burden to justify the warrantless search. | Crouse | Hamilton |
2/6/2026
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2/6/2026
| 2026-Ohio-380 |
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State v. Harrell
| C-250344 | SENTENCING — R.C. 2929.13(B) — COMPLICITY —AIDING OR ABETTING — THEFT: Defendant’s 12-month prison sentence for a nonviolent fifth-degree felony is not contrary to law because defendant violated the terms of her bond when she failed to appear at a pretrial hearing and that violation triggered the trial court’s discretionary authority under R.C. 2929.13(B)(1)(b)(iii) to sentence defendant to a prison term. Defendant’s conviction for aiding or abetting a retail theft was supported by sufficient evidence and not contrary to the manifest weight of the evidence where the record shows that defendant drove the principal actors to the retail store, brought merchandise to the principal actors in the store, and reconvened with the principal actors following the theft. | Bock | Hamilton |
2/6/2026
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2/6/2026
| 2026-Ohio-381 |
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In re Q.R.
| C-250061 | ABUSE OF DISCRETION – ATTORNEY FEES – CONTEMPT – JUVENILE – SERVICE – WAIVER: Where Mother’s testimony indicated that she understood that the juvenile court’s shared parenting order required her to afford Father a 30-minute grace period when picking up the child for visitation, the juvenile court did not abuse its discretion in finding Mother in contempt for failing to wait the entire 30 minutes. Where Mother failed to assert her unclean hands argument in the juvenile court, she has waived the argument for appellate review. Where Mother failed to provide a transcript of the hearing where the juvenile court determined she did not perfect service of her objections, and the determination of the sufficiency of service is within the juvenile court’s discretion, the juvenile court did not abuse its discretion in finding Mother failed to perfect service. Where the juvenile court awarded Father $1,000 in attorney’s fees, which was less than the requested $4,025, the juvenile court’s award was not an abuse of discretion. | Nestor | Hamilton |
2/4/2026
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2/4/2026
| 2026-Ohio-341 |
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State v. Hammock
| C-250233 | NORWOOD Cod.Ord. 1331.10 — SUFFICIENCY OF THE EVIDENCE: Testimony from a code official that he intended for the placard posted by the Board of Health to remain on defendant’s property and that no person, other than the code official, was to remove the placard, was sufficient to establish that defendant did not have permission to remove the placard and to support a conviction for a violation of Norwood Cod.Ord. 1331.10(c), which prohibits the removal of a placard posted by an official responsible for enforcing the Norwood Property Maintenance Code. | Crouse | Hamilton |
2/4/2026
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2/4/2026
| 2026-Ohio-342 |
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Ragouzis v. Madison House Condominium Owners Assn.
| C-240624 | DISMISSAL OF COMPLAINT WITH PREJUDICE – FAILURE TO FOLLOW COURT ORDERS – CONTEMPT – SANCTIONS – CIV.R. 41(B)(1): The trial court did not abuse its discretion is dismissing plaintiff's complaint against condominium owners' association and other defendants in which plaintiff claimed defendants failed to properly maintain and repair condominiums in a 175-unit high-rise building. Defendants counterclaimed, claiming plaintiff interfered with the association's vendors and contractors, breached a restrictive covenant, and had a well-documented history of harassing and wrongfully interfering with vendor and contractor work in the building. Trial court correctly found that plaintiff had engaged in persistent, flagrant, and substantial disregard for the trial court's multiple rules and orders not to interfere with repair work. The dismissal of plaintiff's complaint against the defendants with prejudice was within the trial court's discretion under Civ. R. 41(B)(1), and the court was not required – as plaintiff claimed – to first apply progressive disciplinary procedures before dismissal, or to consider plaintiff's status as a pro se party. Plaintiff's due process rights also were not violated by the trial court's failure to wait 14 days after the filing of a show cause order to allow plaintiff to file a response since plaintiff failed to raise the issue before the trial court and was present and had the opportunity to present a defense during the show cause hearing. | M. Powell | Hamilton |
1/30/2026
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1/30/2026
| 2026-Ohio-290 |
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State v. Williams
| C-250182 | POSTCONVICTION — R.C. 2953.21 — FINDINGS OF FACT AND CONCLUSIONS OF LAW — PROCEDURE — AMENDMENT OF PETITIONS The trial court erred by denying petitioner’s timely, amended first petition for postconviction relief without making findings of fact and conclusions of law, as required by R.C. 2953.21(D) and (H). | Crouse | Hamilton |
1/30/2026
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1/30/2026
| 2026-Ohio-291 |
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In re T.C.
| C-250010 | PARENTAL VISITATION — R.C. 3109.05 — BEST INTEREST: The juvenile court’s judgment awarding father limited supervised visitation with his son was not an abuse of discretion where the juvenile court’s factual findings are supported by competent credible evidence in the record and father’s conduct directed towards mother supported the juvenile court’s conclusion that father would struggle to coparent with mother. | Bock | Hamilton |
1/28/2026
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1/28/2026
| 2026-Ohio-240 |
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State v. Dunn
| C-250257 | RESTITUTION — MARSY’S LAW — R.C. 2929.28 — ECONOMIC LOSS — ABILITY TO PAY : The trial court erred in denying victims-appellants’ restitution request based on defendant’s inability to pay where the trial court lacked any evidence of defendant’s inability to pay and victims have a right to restitution under the Ohio Constitution and R.C. 2929.28. | Bock | Hamilton |
1/28/2026
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1/28/2026
| 2026-Ohio-241 |
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