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Case CaptionCase No.Topics and IssuesAuthorCitation / CountyDecidedPostedWebCite
State v. Snyder 6-24-04Crim.R. 11; Change of Plea; Self-Incrimination. Because the trial court failed to comply with Crim.R. 11(C)(2)(c) during the plea colloquy, defendant-appellant's guilty plea was not entered knowingly, intelligently, and voluntarily.MillerHardin 10/7/2024 10/7/2024 2024-Ohio-4860
State v. Williams 2-24-02FELONY SENTENCING; R.C. 2953.08(G)(2)(a); R.C. 2929.11; R.C. 2929.12. Defendant-appellant’s sentence is not contrary to law because the sentence is within the permissible statutory range and the trial court properly considered R.C. 2929.11 and 2929.12.ZimmermanAuglaize 10/7/2024 10/7/2024 2024-Ohio-4837
In re E.R. 12-24-02; 12-24-03Permanent Custody; Motion to Dismiss. Trial court erred in sua sponte reconsidering its judgment unconditionally dismissing a case. Once a case has been unconditionally dismissed, the trial court lacks jurisdiction to enter any judgment.WillamowskiPutnam 10/7/2024 10/7/2024 2024-Ohio-4840
In re T.S. 14-24-14; 14-24-15; 14-24-16; 14-24-17; 14-24-18JURISDICTION OF JUVENILE COURT; R.C. 2152.02(C)(6); PETITION FOR POST-CONVICTION RELIEF; R.C. 2953.21. The juvenile court not err in dismissing the petitioner-appellant’s petition for post-conviction relief. The juvenile court lacked jurisdiction to consider the petition for post-conviction relief since the petition was filed after the petitioner-appellant had attained the age of 21.ZimmermanUnion 10/7/2024 10/7/2024 2024-Ohio-4841
State v. Wolfe 14-23-35JURY LIMITING INSTRUCTION; ADMISSION AND EXCLUSION OF EVIDENCE; HEARSAY; EVID.R. 803(4); SUFFICIENCY OF THE EVIDENCE; RAPE; ATTEMPTED GROSS SEXUAL IMPOSITION; DATE OF OFFENSE; INEFFECTIVE ASSISTANCE OF TRIAL COUNSEL; SENTENCING; CONSECUTIVE SENTENCES. The trial court’s unsolicited limiting instruction did not rise to the level of plain error. The trial court did not abuse its discretion by permitting the jury to view a video recording of the victim’s interview with a social worker and forensic interviewer at the Center for Family Safety and Healing at Nationwide Children’s Hospital or by admitting the video and corresponding report into evidence. The defendant-appellant’s rape and attempted-gross-sexual-imposition convictions are based on sufficient evidence. The defendant-appellant’s trial counsel was not ineffective for failing to object to the State’s reference to inadmissible hearsay, prior-bad-acts, evidence, or the defendant-appellant’s pre-arrest silence, or by failing to request a mistrial. The defendant-appellant’s sentence is not contrary to law.ZimmermanUnion 10/7/2024 10/7/2024 2024-Ohio-4861
State v. Reed 5-23-50Sufficient Evidence; Manifest Weight; Expert Testimony. In evaluating a sufficiency of the evidence challenge, the appellate court must examine the record in a light most favorable to the prosecution to determine whether some evidence was produced at trial to substantiate each of the essential elements of the crime. To establish a conviction for aggravated murder in violation of R.C. 2903.01(A), the State must prove that the defendant purposely, and with prior calculation and design, caused the death of another. The failure of the State to request that a witness be formally designated as an expert does not rise to the level of plain error where the witness gave testimony regarding his or her qualifications.WillamowskiHancock 10/7/2024 10/7/2024 2024-Ohio-4838
State v. Marks 15-23-11 & 15-23-12Joinder; Crim.R. 14; Motion for Change of Venue; Extortion; R.C. 2905.11(A)(3); Protected Speech; Jury Instructions. The trial court did not abuse its discretion in joining offenses for trial where the evidence of each crime was simple and distinct. The trial court did not abuse its discretion in denying defendant-appellant's motion for change of venue. Defendant-appellant's convictions were not against the manifest weight or sufficiency of the evidence. Defendant-appellant did not establish plain-error relief was warranted regarding the jury instructions.MillerVan Wert 10/7/2024 10/7/2024 2024-Ohio-4863
Fertilizer Storage Co., L.L.C. v. Heartland Bank 2-23-16SUMMARY JUDGMENT; FRAUD. The trial court did not err by granting summary judgment in favor of defendants-appellees and dismissing plaintiffs-appellants’ fraud claim. Because plaintiffs-appellants failed to read the loan documents before signing them, plaintiffs-appellants cannot establish justifiable reliance on representations made by defendants-appellees regarding any prepayment penalties contained in the documents.ZimmermanAuglaize 10/7/2024 10/7/2024 2024-Ohio-4836
Bayliff v. Stokes Twp. Bd. of Zoning Appeals 8-24-12Administrative appeal; Zoning; Variance; Unnecessary hardship. The trial court erred in affirming a township board of zoning appeals' grant of a variance application relating to setback requirements when an unnecessary hardship was not established and where the trial court utilized an inapplicable legal standard.WaldickLogan 10/7/2024 10/7/2024 2024-Ohio-4839
State v. Webb 14-23-38FELONY SENTENCING; R.C. 2953.08(G)(2); R.C. 2929.11; R.C. 2929.12; R.C. 2921.331(C)(5)(b); CONSECUTIVE SENTENCES; R.C. 2929.14(C)(3). The defendant-appellant’s sentence is not contrary to law because it is within the sentencing range and the trial court properly considered R.C. 2929.11, 2929.12, and 2921.331(C)(5)(b). The defendant-appellant’s consecutive sentences are not contrary to law because consecutive sentences are mandatory under R.C. 2929.14(C)(3) since the defendant-appellant was convicted of a felony violation of R.C. 2921.331.ZimmermanUnion 10/7/2024 10/7/2024 2024-Ohio-4862
Akroyd v. Akroyd 5-24-09R.C. 3105.011; Civ.R. 75. Trial court did not err by using equitable powers to modify visitation.WaldickHancock 9/23/2024 9/23/2024 2024-Ohio-4631
State v. Manns 6-23-17Felony Sentencing; R.C. 2953.08; Contrary to Law; Presentence Investigation; Plain Error. A trial court's reliance on evidence from outside the record may violate a defendant's due process rights and render a sentence contrary to law. However, references to information from a co-defendant's case after the defendant's sentence has been imposed do not necessarily constitute plain error where the findings made in support of the defendant's sentence have an independent basis in the record or where the trial court does not rely on such information in fashioning a sentence. A presentence investigation report is confidential. A defendant does not have the right to access a co-defendant's PSI from another case. A trial court's reference to a co-defendant's PSI does not constitute plain error where the record contains no indication that the sentence imposed on the defendant was based on any information contained therein.WillamowskiHardin 9/23/2024 9/23/2024 2024-Ohio-4632
In re S.K. 4-24-07, 4-24-08, 4-24-09R.C. 2151.03(A)(2); Neglected Children; R.C. 2151.04(C); Dependent Children. The trial court did not err in finding, by clear and convincing evidence, that Appellant's children were neglected under R.C. 2151.03. The trial court did not err in finding, by clear and convincing evidence, that Appellant's children were dependent under R.C. 2151.04.MillerDefiance 9/23/2024 9/23/2024 2024-Ohio-4629
Cornwell v. Eufracio 13-24-17; 13-24-18PARENTAL RIGHTS AND RESPONSIBILITIES; R.C. 3109.04; IN CAMERA INTERVIEW OF A CHILD. The trial court did not abuse its discretion by allocating the parties’ parental rights and responsibilities or by designating petitioner-appellee as the children’s residential parent and legal custodian.ZimmermanSeneca 9/23/2024 9/23/2024 2024-Ohio-4634
Evans v. Walmart Defiance Supercenter #5385 4-24-13Summary Judgment; Slip and Fall; Constructive Notice; Duty of Care. To recover from a shopkeeper in a slip and fall case, the plaintiff must demonstrate that the defendant created the hazard, had actual knowledge of the hazard, or had constructive notice of the hazard. In turn, the plaintiff must present some evidence as to how long the condition was present to establish constructive notice. Such evidence is required because, without information about how long a condition existed, no inference can be drawn as to whether the shopkeeper breached a duty of care with regard to that condition.WillamowskiDefiance 9/23/2024 9/23/2024 2024-Ohio-4630
Gardner v. XPO Logistics Freight, Inc. 9-23-80Civ.R. 53(D)(3); Magistrate's Decision; Objections; Summary Judgment; Assured Clear Distance Ahead; Peripheral Object; Sudden Emergence. The Ohio Rules of Civil Procedure give a party fourteen days from the issuance of a magistrate's decision to file written objections with the trial court. With the exception of raising a claim of plain error, a party may not assign error on appeal unless that party previously filed a corresponding objection to the magistrate's decision in compliance with Civ.R. 53(D)(3)(b). Thus, the failure to file objections to the magistrate's decision waives all but plain error on appeal. When a tractor-trailer was driving in the only eastbound lane on a roadway and activated its turn signal before making a wide-right turn, the tractor-trailer was clearly indicating that it was going to remain in the line of travel ahead of the motorcycle following behind it until the right turn had been completed. For this reason, the tractor-trailer was not a peripheral object that suddenly emerged into the assured clear distance of the motorcycle.WillamowskiMarion 9/23/2024 9/23/2024 2024-Ohio-4633
Starr v. Statler-Houchin 4-23-18REALLOCATION OF PARENTAL RIGHTS AND RESPONSIBILITIES; SUBJECT MATTER JURISDICTION; UNIFORM CHILD CUSTODY JURISDICTION AND ENFORCEMENT ACT; R.C. 3127.15(A); DOCTRINE OF JUDICIAL ESTOPPEL; CHANGE OF CIRCUMSTANCES; BEST INTERESTS; R.C. 3109.04. The trial court did not abuse its discretion by exercising its jurisdiction under the UCCJEA since it possessed home-state jurisdiction under R.C. 3127.15(A)(1). Petitioner-appellant is judicially estopped from raising her jurisdictional argument since she conceded the facts underlying the legal conclusion that Ohio was [the child’s] home state at the time this matter commenced. The trial court did not abuse its discretion by modifying the shared-parenting decree and by concluding that it is in child’s best interest for petitioner-appellee to have residential and legal custody of the child.ZimmermanDefiance 9/23/2024 9/23/2024 2024-Ohio-4628
State v. Jones 15-24-01SUFFICIENCY OF THE EVIDENCE; IDENTITY; COMPLICITY TO ATTEMPTED MURDER; KIDNAPPING; FELONIOUS ASSAULT; AGGRAVATED BURGLARY; ALLIED OFFENSES OF SIMILAR IMPORT; SENTENCING; CONSECUTIVE SENTENCES; INEFFECTIVE ASSISTANCE OF TRIAL COUNSEL; MOTION FOR NEW TRIAL; CRIM.R. 33. The defendant-appellant’s complicity-to-attempted-murder, kidnapping, felonious-assault, and aggravated-burglary convictions are based on sufficient evidence. The defendant-appellant’s complicity-to-attempted-murder, kidnapping, felonious-assault, and aggravated-burglary convictions are not allied offenses of similar import. The trial court made the appropriate R.C. 2929.14(C)(4) findings before imposing consecutive sentences and incorporated those findings into its sentencing entry and those findings are not clearly and convincingly unsupported by the record. The defendant-appellant’s trial counsel was not ineffective for failing to object to the jury pool. The trial court did not abuse its discretion by denying the defendant-appellant’s motion for new trial under Crim.R. 33(A)(1), (4).ZimmermanVan Wert 9/16/2024 9/16/2024 2024-Ohio-4538
State v. Moore 5-24-05Restitution; Jointly-Recommended Sentence; Indefinite Sentencing; R.C. 2929.19(B)(2)(c). The trial court did not err by ordering the defendant-appellant to pay restitution in accordance with the parties' agreement. The trial court satisfied the notification requirements in R.C. 2929.19(B)(2)(c).MillerHancock 9/16/2024 9/16/2024 2024-Ohio-4536
State v. Taylor 9-24-02Presentence motion to withdraw no contest plea; Crim.R. 32.1. The trial court did not abuse its discretion in denying the defendant-appellant's presentence motion to withdraw his plea of no contest.WaldickMarion 9/16/2024 9/16/2024 2024-Ohio-4537
State v. Glass 1-23-55Ineffective assistance of counsel; Voir dire; Fair and impartial jury; Actual prejudice; Presumed prejudice. Defendant-appellant's trial counsel was ineffective in failing to voir dire a prospective juror whose son was the primary witness for the prosecution.WaldickAllen 9/16/2024 9/16/2024 2024-Ohio-4535
State v. Baker 1-23-59PETITION FOR POST-CONVICTION RELIEF; R.C. 2953.21; R.C. 2953.23(A). The defendant-appellant’s petition for post-conviction relief is untimely because it was filed many years after the 365-day deadline set forth in R.C. 2953.21. Because the defendant-appellant failed to establish that he is entitled to file a delayed petition for post-conviction relief under one of the exceptions in R.C. 2953.23(A), the trial court was without jurisdiction to consider the untimely petition.ZimmermanAllen 9/9/2024 9/9/2024 2024-Ohio-4448
In re E.A. 3-23-36Final Appealable Order. The trial court's judgment entry granting temporary custody of the child to a non-parent was not a final, appealable order.MillerCrawford 9/9/2024 9/9/2024 2024-Ohio-4449
In re C.W. 5-23-51Permanent Custody; Reasonable Efforts; Ineffective Assistance of Counsel. Trial court did not err by determining that Children's Protective Services Unit ("CPSU") engaged in reasonable efforts to support reunification. Appellant did not demonstrate ineffective assistance of counsel.WaldickHancock 9/3/2024 9/3/2024 2024-Ohio-3366
State v. Parsons 7-23-20Crim.R. 33(B); Motion for Leave to File a Motion for a New Trial. The trial court did not apply the proper legal standard and procedure in deciding appellant-defendant's motion for leave to file an untimely motion for a new trial based on alleged newly discovered evidence, as set forth in Criminal Rule 33. The judgment of the trial court is reversed and the case is remanded for the trial court to consider anew the motion for leave under the proper standard.MillerHenry 9/3/2024 9/3/2024 2024-Ohio-3367
State v. Sanders 1-17-36SUFFICIENCY OF THE EVIDENCE; MANIFEST WEIGHT OF THE EVIDENCE; KIDNAPPING; AGGRAVATED BURGLARY; INEFFECTIVE ASSISTANCE OF COUNSEL. The defendant-appellant’s kidnapping and aggravated-burglary convictions are based on sufficient evidence and are not against the manifest weight of the evidence. The trial court did not abuse its discretion by denying the defendant-appellant’s motion to remove his appointed trial counsel since the defendant-appellant failed to establish that a breakdown of the attorney-client relationship had occurred. The defendant-appellant’s trial counsel was not ineffective since the defendant-appellant failed to demonstrate that the actions of his trial counsel were not part of a trial strategy and that the outcome of the trial would have been different.ZimmermanAllen 9/3/2024 9/3/2024 2024-Ohio-3365
Dublin City Schools Bd. of Edn. v. Union Cty. Bd. of Revision 14-24-02, 14-24-03, 14-24-04, 14-24-05, 14-24-06, 14-24-07, 14-24-08, 14-24-09R.C. 2506.01; R.C. 5717.01; R.C. 5717.05; Standing of boards of education to appeal board of revision decisions to common pleas court. The trial court did not err in dismissing the appeals filed the boards of education in these consolidated cases.WaldickUnion 9/3/2024 9/3/2024 2024-Ohio-3368
State v. Critten 13-23-33Jail-time credit; Confinement; Judicial Release. The trial court did not abuse its discretion by determining that a specific residential-treatment program did not constitute confinement for the purpose of R.C. 2967.191.MillerSeneca 8/26/2024 8/26/2024 2024-Ohio-3242
State v. Clark 9-23-74Sufficiency of the Evidence; Manifest Weight of the Evidence; Assault. The evidence was sufficient to support the conviction of assault and was not against the manifest weight of the evidence.WillamowskiMarion 8/26/2024 8/26/2024 2024-Ohio-3240
Smith v. Wells 17-24-01Civ.R. 41; Civ.R. 60(B). Trial court did not err by denying Civ.R. 60(B) motion without hearing.WaldickShelby 8/26/2024 8/26/2024 2024-Ohio-3243
State v. James 13-23-27Sufficiency of the Evidence; Civil Protection Order; Burglary. Evidence was sufficient to show that defendant committed the offenses for which he was indicted. R.C. 2929.27 does not require that defendant was served with the CPO, only that he or she knew that a CPO was likely to have existed.WillamowskiSeneca 8/26/2024 8/26/2024 2024-Ohio-3241
State v. Rice 8-24-13Misdemeanor Sentencing; Abuse of Discretion; R.C. 2929.21; R.C. 2929.22; Purposes of Sentencing. A trial court is to be guided by the purposes set forth in R.C. 2929.21 while imposing a sentence for a misdemeanor. The trial court is also to consider the list of factors set forth in R.C. 2929.22(B) in fashioning a sentence.WillamowskiLogan 8/19/2024 8/19/2024 2024-Ohio-3156
State v. Lombardo 1-23-61Evid.R. 404(B); Evid.R. 403. Trial court did not err by providing limiting instruction regarding unsolicited statements of witness who claimed defendant had spit on her in the past.WaldickAllen 8/19/2024 8/19/2024 2024-Ohio-3155
State v. Pryor 1-22-48, 1-22-49, 1-23-46, 1-23-47Manifest Weight; Domestic Violence; Unauthorized Use of a Vehicle; Burglary; Motion for a New Trial; Abuse of Discretion; Crim.R. 33; Juror Misconduct; Nondisclosure; Verdict Form; R.C. 2945.75. Defendant-appellant’s convictions for domestic violence, unauthorized use of a vehicle, and burglary were not against the manifest weight of the evidence. The trial court did not err by denying defendant-appellant’s motion for a new trial. The verdict forms complied with R.C. 2945.75.MillerAllen 8/19/2024 8/19/2024 2024-Ohio-3154
State v. Lang 16-23-10Restitution; R.C. 2929.18(A)(1). The trial court did not abuse its discretion in deciding a preponderance of the evidence established that victim suffered an economic loss, as a direct and proximate result of appellant-defendant's theft, in the amount ordered as restitution.MillerWyandot 8/19/2024 8/19/2024 2024-Ohio-3157
State v. Samuels-Thomas 14-23-42INEFFECTIVE ASSISTANCE OF COUNSEL; VENUE; DOUBLE JEOPARDY; GUILTY PLEA; WAIVER. The defendant-appellant waived any error unrelated to his change-of-plea by pleading guilty to the counts of the indictment. Even so, the defendant-appellant’s trial counsel was not ineffective because the defendant-appellant failed to meet his burden of proving that, but for his alleged trial counsel’s errors, he would not have pleaded guilty.ZimmermanUnion 8/12/2024 8/12/2024 2024-Ohio-3059
State v. Pirani 15-23-09Speedy Trial; Sufficient Evidence; Ineffective Assistance of Counsel; R.C. 2909.23(A)(1)(c); True Threats. The failure to raise a speedy trial challenge before the trial court generally waives the issue on appeal. Threats are not protected speech. The State does not need to prove that a defendant intended to act on a threat in order to establish a conviction for violating R.C. 2909.23(A). To establish an ineffective assistance of counsel claim, the appellant must demonstrate that trial counsel's deficient performance prejudiced the Defense. The failure to raise meritless arguments does not constitute deficient performance.WillamowskiVan Wert 8/12/2024 8/12/2024 2024-Ohio-3060
State v. Higgins 8-23-19Domestic Violence; Manifest Weight; Witness Credibility; Finder of Fact. A conviction is not against the manifest weight of the evidence simply because conflicting testimony was presented at trial. Further, a finder of fact is free to believe some, all, or none of a witness's trial testimony. Appellate courts give deference to the credibility determinations of the finder of fact.WillamowskiLogan 8/12/2024 8/12/2024 2024-Ohio-3055
State v. Roeder 6-23-18Felonious Assault; Domestic Violence; Not Guilty by Reason of Insanity ("NGRI"); Merger of Sentences, Sentence Contrary to Law. Trial court did not abuse its discretion when determining that the NGRI defense did not apply because two credible experts testified to competing views and the trial court determined that defendant had not shown the NGRI by a preponderance of the evidence. The sentences for felonious assault and domestic violence did not merge when they were separate acts with separate harm. The trial court erred by sentencing defendant to 180 days for a violation of R.C. 2919.25(C), which is a misdemeanor of the fourth degree with a maximum sentence of 30 days.WillamowskiHardin 8/12/2024 8/12/2024 2024-Ohio-3054
Pfeifer Farms, Inc. v. Hill 9-23-79Civ.R. 11; Sanctions; R.C. 2323.51; Frivolous Conduct. Trial court's determination that attorney for defendants engaged in sanctionable/frivolous conduct is supported by the record and applicable legal authority.WaldickMarion 8/12/2024 8/12/2024 2024-Ohio-3057
State v. Davis 1-24-13Assault; Sufficiency; Manifest Weight. Assault conviction was supported by the evidence where woman slapped Domino's employee.WaldickAllen 8/12/2024 8/12/2024 2024-Ohio-3053
Baker v. Deatrick 11-23-08CHILD TAX CREDIT; R.C. 3119.82; ABUSE OF DISCRETION; MANIFEST WEIGHT OF THE EVIDENCE. The trial court did not abuse its discretion by ordering the parties to alternate claiming the child on their respective income tax returns for purposes of the child tax credit. The trial court considered the factors set forth in R.C. 3119.82 and determined that it is in the best interests of the child to allocate the benefit of the child tax credit between mother and father. The trial court's decision is not an abuse of discretion because it is supported by competent, credible evidence.ZimmermanPaulding 8/12/2024 8/12/2024 2024-Ohio-3058
State v. Glenn 1-23-67R.C. 2929.13; Negotiated Guilty Plea; Sentencing. The trial court did not err in sentencing defendant-appellant to a mandatory term of imprisonment on the involuntary manslaughter conviction. Defendant-appellant was not induced to enter his plea by the alleged misinformation given by the trial court regarding judicial release.MillerAllen 8/12/2024 8/12/2024 2024-Ohio-3052
Redman v. Hope Harbor Baptist Church 8-24-02Forced Entry and Detainer ("FED"); Statute of Frauds. Trial court did not err by determining that church could not be evicted for non-payment of rent when oral agreement did not require rent payment.WaldickLogan 8/12/2024 8/12/2024 2024-Ohio-3056
State v. Jones 1-23-17; 1-23-18; 1-23-19MOTION TO DISMISS; 2ND AMENDMENT; R.C. 2941.141(A); FIREARM SPECIFICATION; SPEEDY TRIAL; R.C. 2945.71; R.C. 2945.72; BCI LABORATORY ANALYSIS; ADDITIONAL FACTS; NEW SPEEDY TRIAL CLOCK; ALLIED OFFENSES OF SIMILAR IMPORT; BATSON CHALLENGE; VOIR DIRE. The trial court did not abuse its discretion by denying the defendant-appellant’s motion to dismiss the firearm specifications because R.C. 2941.141(A) is not unconstitutional (facially or as applied to the defendant-appellant) under New York State Rifle & Pistol Assn., Inc. v. Bruen, 597 U.S. 1, 142 S.Ct. 2111 (2021). The defendant-appellant’s speedy-trial rights were not violated because a new speedy-trial began to run from the subsequent indictment since the State did not have all of the information necessary to support the defendant-appellant’s aggravated-possession-of-drugs charges at the time of the original indictment. The trial court did not err by failing to merge the defendant-appellant’s aggravated-possession-of-drugs convictions. The trial court’s decision rejecting the defendant-appellant’s Batson challenge was not clearly erroneous.ZimmermanAllen 8/5/2024 8/5/2024 2024-Ohio-2959
State v. Morris 1-23-24Manifest Weight; Self-Defense; Impeachment; Evid.R. 613; Reagan Tokes. Murder conviction was not against the manifest weight of the evidence. Introduction of improper impeachment testimony did not impact outcome of the trial.ZmudaAllen 8/5/2024 8/5/2024 2024-Ohio-2960
Kasha Foods, L.L.C. v. Diamantopoulos 13-24-04R.C. 4505.10; Certificate of Title; Vehicles; R.C. 1309.204; After-Acquired Collateral. The trial court did not err in denying plaintiff-appellant's motion for a court order directing the county clerk of courts to issue a certificate of title for a vehicle because plaintiff-appellant did not show it employed the remedies contained within R.C. 4505.10(A) that are a prerequisite to petitioning the trial court to order the clerk to issue the certificate of title.MillerSeneca 8/5/2024 8/5/2024 2024-Ohio-2962
In re N.A. 7-23-16R.C. 2151.414(A)(2); Time Limits; Permanent Custody; Abuse of Discretion. R.C. 2151.414(A)(2) sets guideline time limits in permanent custody action. Trial court abused its discretion by strictly following suggested guidelines to the unconscionable detriment of minor child.WaldickHenry 8/5/2024 8/5/2024 2024-Ohio-2961
State v. Bingham 1-23-29 & 1-23-30Post-conviction Motion to Withdraw No-contest Plea; Crim.R. 16; Brady Violation. Defendant-appellant did not establish manifest injustice, as required under Crim.R. 32.1 to withdraw his plea of no-contest after sentencing. The trial court did not abuse its discretion in deciding not to hold a hearing on the post-sentence motion to withdraw a plea.MillerAllen 7/29/2024 7/29/2024 2024-Ohio-2861
State v. Doseck 8-23-29Consecutive Sentences; Protect the Public. Record supported the findings of the trial court that there were multiple courses of conduct and that defendant had a lengthy criminal history.WillamowskiLogan 7/29/2024 7/29/2024 2024-Ohio-2862
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