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State v. Barker
| 2025-CA-75 | Appellant pleaded guilty to rape (child less than 13 years of age), and he was sentenced accordingly. Approximately three years later, appellant moved to withdraw his plea. The trial court did not abuse its discretion in overruling appellant’s motion. The record does not reveal any grounds for a finding of manifest injustice that would have supported withdrawal of the guilty plea. Judgment affirmed. | Tucker | Clark |
5/1/2026
|
5/1/2026
| 2026-Ohio-1579 |
|
State v. Kintz
| 2025-CA-48 | Appellant’s 36-month sentence for a third-degree felony upon his admission to violating community control sanctions is not clearly and convincingly contrary to law. The sentence is within the statutory range for a third-degree felony. The trial court advised appellant at his original sentencing hearing that if he violated community control sanctions, it could impose up to a 36-month prison sentence. Prior to imposing appellant’s sentence, the trial court stated that it had considered R.C. 2929.11 and 2929.12. Appellant’s sentence is also not contrary to law because he was charged with, but not convicted of, new offenses while on community control sanctions. Appellant did not raise this issue with the trial court. Rather he waived the probable cause and evidentiary hearings associated with his revocation proceedings. Nothing established plain error in the trial court’s judgment, because appellant admitted to other violations of community control sanctions. Judgment affirmed. | Hanseman | Greene |
5/1/2026
|
5/1/2026
| 2026-Ohio-1584 |
|
State v. Shafer
| 2025-CA-38 | The record does not support appellant’s ineffective assistance of trial counsel claim. The record lacks a transcript of the plea hearing, and appellant’s argument relies entirely on evidence outside the record. Judgment affirmed. | Lewis | Miami |
5/1/2026
|
5/1/2026
| 2026-Ohio-1586 |
|
Aboagye v. Peake
| 30627 | Although appellant alleged a meritorious defense in her Civ.R. 60(B) motion for relief from judgment, she did not establish grounds for relief, and her motion was untimely. Judgment affirmed. | Huffman | Montgomery |
5/1/2026
|
5/1/2026
| 2026-Ohio-1578 |
|
Hendriks v. GNA Canadian Holding Co.
| 30469 | Appellee-cross-appellant, employee, sued for breach of employment contract by appellant-cross-appellee, employer, and employee obtained a favorable jury verdict. The record reveals no grounds for reversing the trial court’s denial of summary judgment for employer. The trial court did not err in declining to admit at trial newly discovered evidence offered by employer. The jury’s verdict is supported by legally sufficient evidence and is not against the weight of the evidence. The record supports the trial court’s decision to award prejudgment interest and the amount of the award. Judgment affirmed. | Tucker | Montgomery |
5/1/2026
|
5/1/2026
| 2026-Ohio-1580 |
|
Henry v. Ohio Dept. of Pub. Safety
| 30604 | The trial court erred in affirming the adjudication order of the Ohio Department of Public Safety that denied appellant’s request for a firearm bearer notation with a revolver designation. Appellant completed the requirements in R.C. 4749.10 and had a firearm bearer notation with a semiautomatic handgun designation. The additional twenty hours of training in Adm.Code 109:2-3-10 required for the revolver designation are unreasonable and conflict with the plain language of R.C. 4749.10. The statute requires only 20 hours of training in “handgun use,” and by statute, both semiautomatic handguns and revolvers are handguns. Judgment reversed. | Lewis | Montgomery |
5/1/2026
|
5/1/2026
| 2026-Ohio-1581 |
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In re Z.B.
| 30690 | The trial court’s judgment entry granting appellee, a public children services agency, permanent custody of appellant’s two minor children is not against the manifest weight of the evidence. The record contains clear and convincing evidence supporting the trial court’s finding that the statutory best-interest factors support an award of permanent custody to the public children services agency. Judgment affirmed. | Tucker | Montgomery |
5/1/2026
|
5/1/2026
| 2026-Ohio-1582 |
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Jones v. Ohio Dept. of Job & Family Servs.
| 30662 | Appellant’s reliance on the Civil Rules in this pro se administrative appeal is misplaced. The Appellate Rules, not the Civil Rules, applied to appellant’s appeal in the trial court from a decision by the Unemployment Compensation Review Commission. The decision of the trial court affirming the commission’s determination that appellant was terminated for just cause was not unlawful, unreasonable, or against the manifest weight of the evidence. Judgment affirmed. | Huffman | Montgomery |
5/1/2026
|
5/1/2026
| 2026-Ohio-1583 |
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Laudato v. Teramana
| 30611 | The trial court did not abuse its discretion in denying appellant’s motion for a new trial based on the trial court’s failure to excuse three prospective jurors for cause. Judgment affirmed. | Epley | Montgomery |
5/1/2026
|
5/1/2026
| 2026-Ohio-1585 |
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State v. Carmichael
| 30618 | The trial court did not err by refusing to instruct appellant’s jury on reasonable parental discipline as an affirmative defense to strangulation and child endangering. The trial court properly overruled appellant’s motion to exclude prior-bad-acts evidence. Appellant’s strangulation and child-endangering convictions are supported by legally sufficient evidence and are not against the manifest weight of the evidence. The record does not support appellant’s claim of ineffective assistance of trial counsel. Judgment affirmed. | Tucker | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1473 |
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State v. Crowder
| 30560 | In this case in which appellant fraudulently obtained title to a home, appellant’s conviction for trespass in a habitation is supported by sufficient evidence and is not against the manifest weight of the evidence. The owner of the house and an electrician hired by the owner were present at the house on days when appellant was trespassing in the house. The trial court did not commit plain error by failing to merge for purposes of sentencing the appellant’s convictions for forgery and tampering with government records because the offenses involved separate victims. Judgment affirmed. | Lewis | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1474 |
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State v. Dillard
| 30634 | Appellant’s claim that his trial counsel provided ineffective assistance by allowing him to enter guilty pleas to his offenses, as opposed to no-contest pleas, fails because appellant did not argue, let alone establish, that the State would have accepted no-contest pleas on the same terms for which it accepted appellant’s guilty pleas. Additionally, the allegedly deficient advice provided by appellant’s trial counsel is outside of the record and cannot support an ineffective-assistance claim on direct appeal. Judgment affirmed. | Hanseman | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1475 |
|
Helton v. Kettering Medical Ctr.
| 30484 | The trial court abused its discretion in granting mental health organization’s untimely motion for leave to amend its answer to add an immunity defense under R.C. 2305.51(B). The immunity offered under R.C. 2305.51(B) is not an affirmative defense because the burden of proof is on the injured patient to establish the elements of a R.C. 2305.51(B) cause of action. Additionally, even if an affirmative defense had been available, the mental health organization was not relieved of its duty to timely raise a defense. The mental health organization waived such amendment by waiting until two weeks before trial to amend its answer, after more than fifteen months of litigation had elapsed. The mental health organization offered no explanation regarding the undue delay, and allowing an amendment at that stage was prejudicial to appellant-patient. The court also erred in granting mental health organization’s second motion for summary judgment because genuine issues of material fact remained for trial on patient’s claims. Judgment reversed and remanded. | Huffman | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1476 |
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In re C.P.
| 30705 | The trial court’s judgments granting permanent custody of three of appellant’s children to a public children services agency are not against the manifest weight of the evidence. Judgments affirmed. | Lewis | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1477 |
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In re P.W.
| 30671 | The trial court did not abuse its discretion in granting legal custody of a minor child to appellee-father. The trial court applied the statutory factors in R.C. 3109.04(F)(1) and rendered a soundly reasoned decision. Even though appellant-mother had been the child’s primary caregiver, that consideration alone is not dispositive of the best interest of the child analysis. The evidence indicated that the child had adjusted well to father’s home and visits, bonded with father and his wife, and was involved in the community where father lived. The evidence supported the trial court’s finding that father was more likely to honor and facilitate parenting-time and visitations with mother. While mother had performed well on her case plan objectives, compliance with a case plan is not dispositive or focused on the best interests of the child. Judgment affirmed. | Hanseman | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1478 |
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State v. Petaway
| 30424 | The trial court did not abuse its discretion in overruling appellant’s motion to suppress the victim’s identification of him, which had been accomplished through a photospread. The trial court did not abuse its discretion in admitting the testimony of appellant’s parole officer, or in admitting evidence of ammunition and extended magazines recovered from appellant’s home and photographs discovered on appellant’s phone. Appellant’s conviction for felonious assault is supported by sufficient evidence and is not against the manifest weight of the evidence. There were not cumulative errors requiring a reversal of appellant’s conviction. Appellant’s sentence under Reagan Tokes Law is neither unconstitutional nor contrary to law. The trial court’s imposition of consecutive sentences for two firearm specifications is not contrary to law. Judgment affirmed. | Lewis | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1479 |
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Pheasant Ridge Assn., Inc. v. Harper
| 30661 | The trial court did not abuse its discretion when it entered a default judgment of foreclosure in favor of appellee. The record demonstrates that appellant failed to file an answer or to otherwise challenge appellee’s complaint in the trial court. To the extent appellant seeks to the challenge the complaint on appeal, he cannot raise arguments that he did not raise in the trial court. Judgment affirmed. | Epley | Montgomery |
4/24/2026
|
4/24/2026
| 2026-Ohio-1480 |
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State v. Boggs
| 2025-CA-22 | The trial court did not err in imposing a term in a community-based correctional facility as part of appellant’s community control sanctions. Appellant’s belief that her rehabilitation did not require time in a community-based correctional facility is not a permissible basis for finding that her sentence is contrary to law. The trial court was not obligated to obtain a professional assessment before ordering appellant to complete a term in a community-based correctional facility. Judgment affirmed. | Tucker | Champaign |
4/24/2026
|
4/24/2026
| 2026-Ohio-1472 |
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State ex rel. Ju v. Mayer
| 2026-CA-26 | Relator’s complaint to compel a municipal court magistrate to process her affidavit in accordance with R.C. 2935.09 and 2935.10 fails to state a claim in mandamus. Respondent has no clear legal duty to, among other things, docket and assign a case number to the affidavit, to refer the affidavit to a prosecutor, or to hold a formal probable cause hearing under the Criminal Rules. A court of appeals lacks original jurisdiction to declare the municipal court’s screening procedure for affidavits to be unlawful or to issue a prohibitory injunction to restrain the procedure. Motion to dismiss sustained. Writ denied. | Per Curiam | Greene |
4/23/2026
|
4/24/2026
| 2026-Ohio-1481 |
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K.S. v. J.C.
| 2025-CA-47 | The trial court did not abuse its discretion when it held that appellant’s objections to a magistrate’s issuance of a domestic violence civil protection order were moot due to the expiration of the protection order during the pendency of the objections before the trial court. Appellant failed to establish any collateral consequences related to the expired protection order. Judgment affirmed. | Epley | Greene |
4/17/2026
|
4/17/2026
| 2026-Ohio-1395 |
|
State v. Sawyer
| 2025-CA-37 | Appellant pleaded guilty to two counts of rape and other charges after being bound over from the juvenile court. Appellant’s guilty plea waived any challenge to the trial court’s denial of his motion to suppress. The juvenile court did not abuse its discretion when it determined that appellant was not amenable to rehabilitation in the juvenile court and transferred his case to the adult court. Judgment affirmed. | Epley | Greene |
4/17/2026
|
4/17/2026
| 2026-Ohio-1398 |
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In re M.D.
| 2025-CA-64 | Appellant-mother lacks standing to claim that father was not properly served with notice of the permanent custody hearing where appellant fails to establish how she was prejudiced by the alleged service error. Appellant also lacks standing to challenge the trial court’s judgment denying her maternal aunt’s third-party motion for legal custody. The trial court’s judgment granting permanent custody of appellant’s children to a public children services agency is supported by sufficient evidence and is not against the manifest weight of the evidence. Judgment affirmed. | Hanseman | Clark |
4/17/2026
|
4/17/2026
| 2026-Ohio-1394 |
|
State v. Hake
| 30643 | The trial court erred in dismissing as void for vagueness a misdemeanor charge against appellee for violating a rule prohibiting the illegal disposal of construction and demolition debris. Judgment reversed and remanded. | Tucker | Montgomery |
4/17/2026
|
4/17/2026
| 2026-Ohio-1393 |
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Leary v. Leary
| 30471 | The trial court’s order awarding $3,000 in attorney’s fees to appellee was an abuse of discretion where the reason given by the trial court for awarding fees was not supported by the record. The trial court’s error in granting a divorce on the grounds of financial misconduct was harmless. Both parties requested a divorce, and sufficient evidence was presented to grant a divorce on the ground of incompatibility. The trial court’s finding that appellant committed financial misconduct is not against the manifest weight of the evidence. As the record clearly demonstrates that appellant engaged in significant financial misconduct, the trial court did not abuse its discretion in rendering its distributive award to appellee. The trial court also did not abuse its discretion in ordering an unequal separation of marital debt because it was equitable under the circumstances. Judgment reversed in part and affirmed in part. | Lewis | Montgomery |
4/17/2026
|
4/17/2026
| 2026-Ohio-1396 |
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State v. Reynolds
| 30512 | In this appeal from a conviction of misdemeanor domestic violence, appellant’s failure to object at his sentencing hearing to the trial court’s restitution order waived all but plain error review. The trial court did not err in awarding restitution for the victim’s medical expenses based on its review of appellant’s presentence investigation report, which contained the victim’s impact statement and medical bills. Judgment affirmed. | Huffman | Montgomery |
4/17/2026
|
4/17/2026
| 2026-Ohio-1397 |
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State v. Warren
| 30539 | The trial court did not abuse its discretion on remand when it denied appellant’s application for postconviction DNA testing based on its finding that the evidence was not scientifically suitable for testing, as required by R.C. 2953.74(C)(2)(c). Judgment affirmed. | Lewis | Montgomery |
4/17/2026
|
4/17/2026
| 2026-Ohio-1399 |
|
Coddington v. Zurawka
| 30687 | The trial court erred in dismissing appellant’s complaint for failure to comply with the presentment requirements of R.C. 2117.06 because appellant’s claims were based on the wrongful withholding of his property rather than claims to assets of the subject estate. Judgment reversed and remanded. | Lewis | Montgomery |
4/10/2026
|
4/10/2026
| 2026-Ohio-1301 |
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Search v. Search
| 30694 | Appellant-father’s argument that the trial court erred in overruling his objections to the magistrate’s decision regarding his parenting time is moot because his daughter turned 18. Following her emancipation, there is no relief regarding parenting time that this court can provide. The dismissal without prejudice of appellant’s motion regarding medical expenses preserved his right to refile his claim for the expenses, so it was not a final, appealable over which this court has jurisdiction. To the extent appellant’s remaining assigned errors relate to parenting time, they are moot, and to the extent they relate to any medical expenses, they are beyond this court’s jurisdiction. Judgment affirmed. | Huffman | Montgomery |
4/10/2026
|
4/10/2026
| 2026-Ohio-1304 |
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Xerion Advanced Battery Corp. v. Certa Vandalia, L.L.C.
| 30553 | The trial court did not err when it determined that the purchase and sale agreement between the parties was ambiguous and allowed for the consideration of extrinsic evidence. Based on the parties’ prior course of conduct with respect to late rent payments and enforcement of the cure payment provision for such late payments, appellant should have provided notice to appellees that they were required to make the cure payment within thirty days of that notice. Because appellant did not provide such notice, the trial court properly granted summary judgment to appellees on their declaratory judgment claim that they had not breached the parties’ agreement. Judgment affirmed. (Tucker, J., dissenting.) | Epley | Montgomery |
4/10/2026
|
4/10/2026
| 2026-Ohio-1307 |
|
Surber v. Greenville Twp. Bd. of Trustees
| 2025-CA-11, 2025-CA-12 | In this administrative appeal, appellee’s improper designation of township board of zoning appeals as the appellee in the notice of appeal filed with the trial court did not divest the court of subject-matter jurisdiction over the administrative appeal, nor did it deprive appellants of standing to appeal to this court. The trial court abused its discretion by reversing the finding of the township board of zoning appeals that a building on appellee’s property was not properly permitted where the board’s decision was supported by a preponderance of reliable, probative, and substantial evidence. The trial court did not abuse its discretion by affirming the board’s finding that two other buildings on appellee’s property were not properly permitted where a preponderance of reliable, probative, and substantial evidence established that those buildings did not qualify for an agricultural exemption and did not have the required zoning permits. Appellee’s claim that the trial court should have applied the doctrine of equitable estoppel based on appellee’s reliance on a former zoning inspector’s representation that two of appellee’s buildings qualified for agricultural exemptions lacks merit because it is well established that equitable estoppel is inapplicable in relation to a political subdivision’s exercise of the government function of enforcing zoning regulations. Any alleged error in the trial court’s exclusion of an affidavit offered into evidence by appellee would have been harmless error because the court considered the affidavit anyway in its decision. Judgment reversed in part and affirmed in part. | Hanseman | Darke |
4/10/2026
|
4/10/2026
| 2026-Ohio-1305 |
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State v. Myers
| 2024-CA-58 | In this death penalty case, the trial court did not err in granting appellee’s motion for leave to file a motion for new trial. However, the court did abuse its discretion in granting a new trial to appellee. The court’s decision was based on unsound reasoning, and the court failed to apply correct legal standards. The trial court also failed to follow statutory requirements with respect to appellee’s petition for postconviction relief and lacked jurisdiction over it. Judgment granting leave to file motion for new trial affirmed. Judgments granting a new trial and granting relief on the postconviction petition reversed and remanded with instructions to enter judgments overruling the motion for new trial and denying the petition for postconviction relief. | Hanseman | Greene |
4/10/2026
|
4/10/2026
| 2026-Ohio-1303 |
|
State v. Taylor
| 2025-CA-51 | Appellant’s 30-month prison sentence for third-degree felony theft from a person in a protected class is not contrary to law. Judgment affirmed. | Hanseman | Greene |
4/10/2026
|
4/10/2026
| 2026-Ohio-1306 |
|
McGhee v. McGhee
| 2025-CA-40 | Appellant’s pro se brief did not comply with App.R. 16 in most respects. Most importantly, the brief did not include a coherent argument asserting how the trial court erred in adopting a magistrate’s decision that denied appellant’s motions related to child custody matters. Judgment affirmed. | Tucker | Miami |
4/10/2026
|
4/10/2026
| 2026-Ohio-1302 |
|
State v. Fowler
| 2025-CA-35 | In pleading guilty to two counts of pandering sexually oriented matter involving a minor or impaired person, appellant admitted the facts set forth in the indictment, and the record reflects that his pleas were entered knowingly, intelligently, and voluntarily. Judgment affirmed. | Huffman | Greene |
4/3/2026
|
4/3/2026
| 2026-Ohio-1212 |
|
State v. Sharpe
| 2025-CA-1 | The trial court did not err in overruling appellant’s motion to dismiss the charges against him on speedy trial grounds, failing to grant a mistrial following the State’s references to an indictment in another case, overruling appellant’s motion for a new trial, or failing to merge three firearm-related offenses as allied offenses of similar import. Appellant’s convictions are supported by legally sufficient evidence and are not against the weight of the evidence. The record also does not support appellant’s claim of ineffective assistance of counsel. Judgment affirmed. | Tucker | Clark |
4/3/2026
|
4/3/2026
| 2026-Ohio-1215 |
|
State v. Coffey
| 30637 | Appellant’s domestic violence conviction is supported by sufficient evidence and is not against the manifest weight of the evidence. Judgment affirmed. | Lewis | Montgomery |
4/3/2026
|
4/3/2026
| 2026-Ohio-1210 |
|
Community Gain v. Johnson
| 30465 | Appellee’s affidavit for service by publication was deficient under Civ.R. 4.4, so the trial court lacked jurisdiction over appellant to render its judgment granting default judgment to appellee, finding appellant’s property to be a public nuisance, and appointing appellee as receiver. Given the trial court’s lack of jurisdiction over appellant, her argument that the trial court should have granted relief from judgment under Civ.R. 60(B) is moot. Judgment vacated and remanded. | Huffman | Montgomery |
4/3/2026
|
4/3/2026
| 2026-Ohio-1211 |
|
In re B.H.
| 30654 | The trial court’s award of permanent custody of appellant’s minor child to a public children services agency was not against the manifest weight of the evidence or based on legally insufficient evidence. The trial court had ample evidence before it to determine that the child was in the agency’s temporary custody for over 12 months during a consecutive 22-month period, notwithstanding appellant’s brief reunification with the child. Ample evidence in the record supported the trial court’s finding that permanent custody to the public children services agency was in the child’s best interests. Appellant’s compliance with her case plan did not outweigh the child’s need for permanency. The public children services agency made reasonable efforts to reunify the child with appellant before seeking permanent custody. Additionally, trial counsel was not ineffective for failing to call witnesses or present evidence during the permanent custody hearing because such decisions are within the realm of reasonable trial strategy. Judgment affirmed. | Hanseman | Montgomery |
4/3/2026
|
4/3/2026
| 2026-Ohio-1213 |
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In re K.M.H.
| 30680 | Mother appeals from a judgment granting legal custody of her two children to their maternal grandparents. The trial court had subject-matter jurisdiction over grandparents’ motions for change of custody. The judgment on appeal is a final appealable order. The magistrate’s decision was adopted by the trial court, and no objections to the magistrate’s decision were filed. No plain error occurred. Judgment affirmed. | Epley | Montgomery |
4/3/2026
|
4/3/2026
| 2026-Ohio-1214 |
|
State v. Farler
| 30494 | Appellant’s claim that his guilty pleas are invalid because the trial court failed to personally address him during the plea hearing and failed to ensure that he understood the effect of his pleas as required by Crim.R. 11(C) lacks merit because the record established that the trial court satisfied those requirements. Appellant’s claim that his trial counsel was ineffective for withdrawing certain arguments from his motion to suppress lacks merit because it is purely speculative as to whether the withdrawn arguments would have been successful, and because withdrawing the arguments was a strategic and tactical decision by counsel that cannot form the basis of an ineffective assistance claim. Appellant’s claim that his trial counsel provided ineffective assistance by failing to advise him to plead guilty as opposed to no contest also fails because the claim relies on evidence outside of the record and therefore cannot be raised on direct appeal. Appellant’s claim that the trial court erred by imposing consecutive sentences lacks merit because the trial court made all the required consecutive-sentence findings at the sentencing hearing and in the sentencing entry, and those findings are not clearly and convincingly unsupported by the record. Appellant’s claim that the trial court erred by failing to consider his present and future ability to pay financial sanctions lacks merit because no such consideration was required given that the trial court imposed only court costs, which are not financial sanctions. Judgment affirmed. | Hanseman | Montgomery |
3/27/2026
|
3/27/2026
| 2026-Ohio-1070 |
|
State v. Ward
| 30526 | Appellant’s conviction was not against the manifest weight of the evidence. The trial record indicated that appellant created the violent situation and that he was not acting out of a legitimate fear of imminent bodily harm when he attacked appellee. Judgment affirmed. | Epley | Montgomery |
3/27/2026
|
3/27/2026
| 2026-Ohio-1074 |
|
State v. Seiker
| 2025-CA-59 | Appellant was sentenced to a prison term of 11 to 16.5 years in connection with her guilty plea to permitting child abuse, a first-degree felony. Her prison sentence was within the permissible statutory range, and the record established that the trial court considered R.C. 2929.11 and 2929.12 in sentencing her. Appellant’s sentence was not contrary to law. Judgment affirmed. | Tucker | Clark |
3/27/2026
|
3/27/2026
| 2026-Ohio-1073 |
|
State v. Windsor
| 2025-CA-31 | Any error as to the form of appellant’s indictment, to which there was no objection, did not constitute plain error. The verdict forms were neither erroneous nor incomplete. Appellant was correctly designated a violent offender. The trial court did not err in the admission of video tape evidence. Appellant’s convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. The trial court did not err by not merging appellant’s convictions of attempted murder and discharge of a firearm on or near prohibited premises. Judgment affirmed. | Tucker | Clark |
3/27/2026
|
3/27/2026
| 2026-Ohio-1075 |
|
State v. Fletcher
| 2025-CA-10 | Appellant’s conviction of involuntary manslaughter for the death of her diabetic, teenage son is supported by sufficient evidence and is not against the manifest weight of the evidence. Judgment affirmed. | Lewis | Darke |
3/27/2026
|
3/27/2026
| 2026-Ohio-1072 |
|
State v. Farwell
| 2025-CA-31 | Appellant argued that his 14-month sentence for strangulation, a felony of the fourth degree, is contrary to law. However, R.C. 2953.08(G)(2) does not allow an appellate court to reweigh the statutory factors contained in R.C. 2929.11 and 2929.12. In addition, appellant’s sentence is not clearly and convincingly contrary to law because the trial court properly considered the purposes and principals of sentencing, considered the seriousness and recidivism factors, and concluded that granting appellant community control would demean the seriousness of his conduct. In addition, the trial court did not rely on incomplete or inaccurate information when imposing appellant’s prison sentence. Judgment affirmed. | Hanseman | Miami |
3/27/2026
|
3/27/2026
| 2026-Ohio-1071 |
|
Legacy Real Estate Investing, L.L.C. v. Maldonado Constr., L.L.C.
| 2025-CA-34 | The trial court abused its discretion when it imposed sanctions against appellant for pursuing an oral motion for Spanish-language interpreter on the morning of trial. The record does not support a reasonable conclusion that the motion was brought for purposes of delay and had caused a delay. Judgment reversed. | Epley | Miami |
3/20/2026
|
3/20/2026
| 2026-Ohio-953 |
|
State v. Allen
| 2025-CA-20 | Appellant’s arguments that the trial court failed to comply with R.C. 2929.19(B)(4) and 2929.15(B)(3) at his disposition hearings are barred by res judicata, and even if the merits could be considered, in the absence of a transcript of those proceedings, we presume regularity. Appellant’s violation of the relocation requirement of his community control sanctions was nontechnical, and he was subject to revocation and incarceration. The trial court did not abuse its discretion in denying appellant’s motion to continue his community control violation hearing. Judgment affirmed. | Huffman | Clark |
3/20/2026
|
3/20/2026
| 2026-Ohio-948 |
|
In re Adoption of J.T.S.
| 2025-CA-62 | The probate court erred in granting appellee-intervenor’s motion to intervene in an adoption proceeding and concluding that appellee was entitled to notice and to withhold his consent in the adoption. Appellee was not entitled to notice of the adoption petition under R.C. 3107.11, nor was his consent required under R.C. 3107.06(B) or 3107.06(A)(3). Appellee had not timely registered with the Ohio Putative Father Registry as required under R.C. 3107.07(B)(1). And although appellee filed a parentage action in the juvenile court nine days before the adoption petition was filed, prior to the petition’s filing, no judicial proceeding had determined that a parent-child relationship existed between appellee and the child. Judgment reversed and remanded. | Huffman | Clark |
3/20/2026
|
3/20/2026
| 2026-Ohio-951 |
|
State v. Martin
| 2025-CA-35 | The trial court erred in accepting appellant’s Alford plea to attempted murder. The trial court did not inquire into the State’s evidence supporting the charge. The trial court also did not inquire about defense counsel’s investigation into the strength of the State’s case or counsel’s recommendations to appellant. The trial court received merely a recitation of appellant’s indictment, which is not a sufficient factual basis for a defendant to enter an Alford plea. Absent a proper Alford plea hearing, appellant’s plea was not knowing, intelligent, and voluntary. Appellant’s plea vacated, trial court judgment reversed, and matter remanded. | Hanseman | Clark |
3/20/2026
|
3/20/2026
| 2026-Ohio-954 |
|
State v. Brown
| 30569 | The trial court did not abuse its discretion in denying appellant’s public records request pursuant to R.C. 149.43(B)(8). Appellant failed to identify a pending proceeding to which the records would be material and how the records would be material to any justiciable claim. Appellant’s right to due process was not violated where he received notice and an opportunity to be heard in both the trial court and on appeal. Judgment affirmed. | Lewis | Montgomery |
3/20/2026
|
3/20/2026
| 2026-Ohio-949 |
|