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| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
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State v. Cunningham
| 2024-CA-81 | The trial court did not abuse its discretion when it overruled appellant’s request for new appointed counsel on the day of trial. Appellant’s guilty plea was knowing, intelligent, and voluntary. The trial court did not err by imposing a maximum prison sentence. Judgment affirmed. | Tucker | Clark |
8/15/2025
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8/15/2025
| 2025-Ohio-2894 |
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State v. Bowman
| 2025-CA-9 | The trial court properly denied appellant’s application for postconviction DNA testing, although its reasoning was flawed. Any exclusion results would not have been outcome determinative because ample non-DNA evidence indicated appellant had murdered his wife. The court followed the statute by giving a reason for denying the application. The fact that the trial court did not give the State a chance to respond to the application before entering its decision did not prejudice appellant. Judgment affirmed. | Epley | Darke |
8/15/2025
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8/15/2025
| 2025-Ohio-2893 |
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State v. Rutter
| 2025-CA-7 | Appellant appealed from the imposition of a six-month jail sentence for violating his community control for nonsupport of dependents. Because he has completely served that jail sentence and his community control has been terminated, his appeal is moot. Appeal dismissed. | Epley | Miami |
8/15/2025
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8/15/2025
| 2025-Ohio-2899 |
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Huber v. Ohio Dept. of Job & Family Servs.
| 30379 | The trial court did not abuse its discretion in affirming an administrative decision that appellant had abandoned his state hearing on the denial of Medicaid benefits. Appellant did not appear for a hearing as scheduled and did not establish good cause for his failure. Judgment affirmed. | Hanseman | Montgomery |
8/15/2025
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8/15/2025
| 2025-Ohio-2895 |
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In re N.R.
| 30348; 30354 | The trial court did not abuse its discretion in granting legal custody of the child to Father. The court reviewed the applicable statutory factors and found that custody to Father was in the child’s best interest. The trial court’s denial of children services’ motion for permanent custody was not against the manifest weight of the evidence and was supported by sufficient evidence, as the agency failed to prove by clear and convincing evidence that permanent custody with the agency was in the child’s best interest. Judgment affirmed. | Hanseman | Montgomery |
8/15/2025
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8/15/2025
| 2025-Ohio-2896 |
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OTARMA v. Miami Twp.
| 30362 | Appellee was entitled to recover attorney fees and costs it incurred in defending appellants pursuant to court orders after no duty to defend existed. However, the trial court erred in failing to hold a hearing on the necessity and reasonableness of the fees and costs. Judgment affirmed in part, reversed in part, and remanded for a hearing on the necessity and reasonableness of attorney fees and costs. | Tucker | Montgomery |
8/15/2025
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8/15/2025
| 2025-Ohio-2897 |
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State v. Ross
| 30398 | The trial court did not abuse its discretion when it denied appellant’s application for post-conviction DNA testing. Any potential exclusion results would not be outcome determinative due to reliable identification and previous DNA results linking appellant to the crime. Judgment affirmed. | Epley | Montgomery |
8/15/2025
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8/15/2025
| 2025-Ohio-2898 |
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State v. Wildman
| 30322 | Appellant’s conviction for abduction was supported by sufficient evidence and was not against the manifest weight of the evidence. Judgment affirmed. | Hanseman | Montgomery |
8/8/2025
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8/8/2025
| 2025-Ohio-2793 |
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State v. Pizzo
| 2025-CA-11 | Appellant appeals from two misdemeanor convictions, claiming that the trial court erred in failing to notify him of his jail-time credit at sentencing. Because appellant has completely served his jail sentence in one case, his appeal from that case is dismissed as moot. No jail term was imposed in the second case. Because no other error has been assigned in the second case, that judgment is affirmed. | Epley | Miami |
8/8/2025
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8/8/2025
| 2025-Ohio-2790 |
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State v. Allen
| 2024-CA-73 | The trial court did not abuse its discretion in denying appellant’s petition for postconviction relief without a hearing. His claims were barred by res judicata or belied by the record. Judgment affirmed. | Lewis | Clark |
8/8/2025
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8/8/2025
| 2025-Ohio-2789 |
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State v. Scerba
| 2024-CA-79 | The trial court erred in denying appellant’s motion to suppress evidence. The police officer’s encounter with appellant was not consensual, the officer did not identify any suspected traffic infraction or proceed as if to issue a citation, and he lacked a reasonable, articulable suspicion of other criminal activity when he detained appellant. Judgment reversed and remanded. | Huffman | Clark |
8/8/2025
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8/8/2025
| 2025-Ohio-2791 |
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State v. Wells
| 2024-CA-82 | The trial court did not abuse its discretion by overruling appellant’s Crim.R. 33 motion for a new trial, which was based on newly discovered evidence of appellant’s purported incompetence to stand trial. Judgment affirmed. | Hanseman | Clark |
8/8/2025
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8/8/2025
| 2025-Ohio-2792 |
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State v. Youngblood
| 2024-CA-72 | The record does not affirmatively demonstrate that the trial court failed to consider the youth-mitigation factors in R.C. 2929.19(B)(1)(b) when sentencing appellant, who was 17 years old when he committed the offense. Judgment affirmed. | Epley | Clark |
8/8/2025
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8/8/2025
| 2025-Ohio-2794 |
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State v. Harrison
| 2024-CA-77 | Appellant’s guilty plea to burglary rendered moot her motion to suppress. The trial court properly advised her of the effect of her plea, and her plea was knowing, intelligent, and voluntary. The trial court did not abuse its discretion in denying appellant’s presentence motion to withdraw her guilty plea, which it found was merely based upon a change of heart. Judgment affirmed. | Huffman | Clark |
8/1/2025
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8/1/2025
| 2025-Ohio-2705 |
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State v. Bansobeza
| 30294 | One of appellant’s kidnapping convictions was not supported by sufficient evidence. The trial court did not abuse its discretion in refusing to admit evidence of appellant’s law-abiding nature, and no cumulative error denied appellant the right to a fair trial. The State concedes error concerning the trial court’s failure to provide Reagan Tokes notifications. Judgment affirmed in part, vacated in part, and reversed and remanded for resentencing. (Huffman, J., concurring.) | Hanseman | Montgomery |
8/1/2025
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8/1/2025
| 2025-Ohio-2704 |
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In re Estate of Oburn
| 30325 | The trial court did not err in denying appellant’s application for a fiduciary fee for her work as administrator of decedent’s estate. Even if appellant was authorized by statute to receive a fiduciary fee based on a wrongful-death settlement, which was not part of decedent’s estate, she failed to identify any source of funds from which she could be compensated. Decedent’s estate had no assets to pay the fiduciary fee, and the wrongful-death statute did not entitle her to a portion of the settlement proceeds. Judgment affirmed. | Tucker | Montgomery |
8/1/2025
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8/1/2025
| 2025-Ohio-2706 |
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State v. Peaks
| 30238 | The juvenile court did not abuse its discretion in granting the State’s motions for discretionary transfers of appellant’s cases to the general division of the common pleas court for trial as an adult. The juvenile court reasonably concluded that appellant, who was 15 years old, was not amenable to care or rehabilitation within the juvenile system and that the safety of the community required that appellant be subject to adult sanctions. Judgment affirmed. | Lewis | Montgomery |
8/1/2025
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8/1/2025
| 2025-Ohio-2707 |
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State v. Russell
| 30421 | Appellant was properly advised regarding post-release control at the sentencing hearing and in the judgment entry. Judgment affirmed. | Huffman | Montgomery |
7/25/2025
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7/25/2025
| 2025-Ohio-2612 |
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Tan v. Dir. of Ohio Dept. of Job & Family Servs.
| 30405 | The trial court did not err in affirming an administrative decision which found that appellant was discharged from her employment for just cause. The decision was lawful and reasonable and was not against the manifest weight of the evidence. There was also no evidence of bias on the hearing officer’s part. Judgment affirmed. | Hanseman | Montgomery |
7/25/2025
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7/25/2025
| 2025-Ohio-2614 |
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State v. Bowen
| 2024-CA-57 | Appellant’s six convictions for theft of drugs were based on insufficient evidence; her conviction for theft of currency was based on sufficient evidence and was not against the manifest weight of the evidence. The record does not reflect that defense counsel rendered ineffective assistance by allegedly failing to review or receive discovery, failing to disclose that he was subject to a stayed suspension of his law license, rejecting a plea offer without discussing it with appellant, or failing to seek dismissal on speedy trial grounds. The prosecutor did not engage in misconduct regarding the disclosure or presentation of evidence or during his closing argument. The trial court did not err in denying appellant’s motion for a new trial. Any error in the trial court’s imposition of a prison sentence rather than community control is moot. Convictions for theft of drugs vacated; conviction for theft affirmed. Remanded for the trial court to facilitate appellant’s release from prison. | Lewis | Clark |
7/25/2025
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7/25/2025
| 2025-Ohio-2610 |
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State v. Taylor
| 2024-CA-74 | Appellant’s counsel was not ineffective for failing to raise competency concerns, because no evidence presented a reasonable question as to whether he was incompetent. Appellant’s sentence was not contrary to law, as it was within the statutory range and the court considered R.C. 2929.11 and R.C. 2929.12. Judgment affirmed. | Epley | Clark |
7/25/2025
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7/25/2025
| 2025-Ohio-2615 |
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State v. Pratt
| 2025-CA-1 | The trial court erred in finding appellant guilty of a violation of R.C. 951.02 following a no contest plea; there was insufficient evidence in the statement of circumstances that appellant had acted recklessly. Judgment vacated. | Lewis | Champaign |
7/25/2025
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7/25/2025
| 2025-Ohio-2611 |
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State v. Armstrong
| 2024-CA-72 | The trial court did not err by denying appellant’s motion to dismiss his case or exclude video evidence where the State’s failure to collect and preserve certain video evidence did not violate Brady v. Maryland, 373 U.S. 83 (1963) or Crim.R. 16. The trial court also did not err by granting two motions in limine filed by the State to exclude evidence that was inadmissible on relevancy grounds. In that appellant entered a no contest plea, the trial court’s ruling on a third motion in limine was not preserved for appellate review because it did not determine the admissibility of evidence with finality. Judgment affirmed. | Hanseman | Greene |
7/25/2025
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7/25/2025
| 2025-Ohio-2609 |
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State v. Russell
| 2024-CA-67 | Appellant’s conviction for felonious assault was not against the manifest weight of the evidence. The trial court reasonably rejected his not guilty by reason of insanity defense. Judgment affirmed. | Lewis | Greene |
7/25/2025
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7/25/2025
| 2025-Ohio-2613 |
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State v. Jacks
| 2024-CA-39 | Appellant was not denied her constitutional or statutory right to a speedy trial, and her trial counsel did not provide ineffective assistance by failing to raise those claims in the trial court. The trial court did not abuse its discretion in failing to declare a mistrial after a key defense witness was allowed to testify remotely via Zoom because she was unable to appear in person. Judgment affirmed. (Huffman, J., concurring.) | Hanseman | Clark |
7/18/2025
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7/18/2025
| 2025-Ohio-2541 |
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State v. Brock
| 30374 | The trial court did not err in refusing to excuse two prospective jurors for cause, admitting challenged video recordings into evidence, or declining to give requested special jury instructions. The appellant’s convictions for gross sexual imposition and illegal use of a minor in nudity-oriented material were based on legally sufficient evidence and were not against the manifest weight of the evidence. Judgment affirmed. | Tucker | Montgomery |
7/18/2025
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7/18/2025
| 2025-Ohio-2538 |
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Fraternal Order of Police v. Dayton
| 30382 | The trial court erred in confirming an arbitration award. The arbitrator did not find any violation of the parties’ collective bargaining agreement ("CBA") itself. Rather, the arbitrator improperly looked outside of the CBA and considered a Police General Order in determining that a police officer was entitled to compensation for lost overtime hours that he did not work while on restricted duty. Judgment reversed and remanded. | Huffman | Montgomery |
7/18/2025
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7/18/2025
| 2025-Ohio-2539 |
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Greenlee v. Richart
| 30302 | The trial court did not err by granting summary judgment in favor of appellee-landlord on appellants’ housing discrimination claim. The trial court’s judgment in favor of another appellee, a neighboring tenant, on several other claims was not against the manifest weight of the evidence. Although the trial court erred by considering the neighboring tenant’s qualified privilege affirmative defense, this error was harmless. The record does not reflect that the trial court interfered with appellants’ presentation of evidence at trial, and the court did not abuse its discretion by overruling appellants’ motion to file a supplemental complaint. Judgment affirmed. | Tucker | Montgomery |
7/18/2025
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7/18/2025
| 2025-Ohio-2540 |
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McManus v. Anderson
| 30401 | The trial court did not err in entering a default judgment against a homeowner in the county treasurer’s tax foreclosure action. The trial court properly authorized service by publication on the homeowner. Judgment affirmed. | Epley | Montgomery |
7/18/2025
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7/18/2025
| 2025-Ohio-2542 |
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In re Adoption of Z.D.W.
| 30380 | The probate court correctly found that appellant’s consent to an adoption was not required because appellant, as a putative father, had not timely registered with the putative father registry. Appellant failed to object in the probate court to the fact that the adoption petition alleged lack of consent under R.C. 3107.07(A) rather than R.C. 3107.07(B). As such, this issue is reviewed for plain error only. Because the error did not affect the outcome and did not cause a manifest miscarriage of justice, there was no plain error. Appellant was aware before the hearing that failure to register under R.C. 3107.07(B)(1) was an issue, the matter was addressed at the hearing, and the court properly applied R.C. 3107.07(B)(1). Judgment affirmed. | Hanseman | Montgomery |
7/11/2025
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7/11/2025
| 2025-Ohio-2465 |
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State v. Jenkins
| 30336 | The trial court failed to give certain advisements required by R.C. 2903.42(A)(1)(a) at appellant’s sentencing hearing, which related to appellant’s duty to enroll in Ohio’s violent offender database. Judgment reversed and remanded with respect to appellant’s duty to enroll in the violent offender database; in all other respects, judgment affirmed. | Hanseman | Montgomery |
7/11/2025
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7/11/2025
| 2025-Ohio-2466 |
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Leal v. Smith
| 30409 | Appellant alleges that errors occurred during the hearing in his divorce proceedings, but he has not filed a transcript of the hearing. Given this, there is nothing for this court to review, and the regularity of the trial court’s proceeding must be presumed. Judgment affirmed. | Tucker | Montgomery |
7/11/2025
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7/11/2025
| 2025-Ohio-2467 |
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State v. Rogan
| 2024-CA-29 | Appellant’s claim of ineffective assistance of counsel relies on evidence outside the record and is not properly raised on direct appeal. The record does not support his claim. Judgment affirmed. | Epley | Champaign |
7/11/2025
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7/11/2025
| 2025-Ohio-2468 |
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State v. Allen
| 2024-CA-67 | Under the totality of the circumstances, a highway patrol trooper possessed reasonable, articulable suspicion of operating a vehicle under the influence when he asked appellant to perform field-sobriety tests. Appellant had no constitutional right to refuse a breathalyzer test, and the trooper’s act of requiring him to take a test he had no legal right to refuse did not provide grounds for suppressing the test result. Appellant also had no constitutional right to speak to an attorney before taking the breathalyzer test. Judgment affirmed. | Tucker | Clark |
7/3/2025
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7/3/2025
| 2025-Ohio-2353 |
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State v. Rhoades
| 2024-CA-19 | Appellant was convicted of assault following a bench trial. The trial court’s verdict, which rejected appellant’s defense of another affirmative defense, was not against the manifest weight of the evidence. Judgment affirmed. | Tucker | Darke |
7/3/2025
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7/3/2025
| 2025-Ohio-2358 |
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In re Z.L.A.
| 2024-CA-78 | The trial court did not abuse its discretion in overruling appellant-father’s legal-custody motion and retaining appellee-mother as legal custodian of the parties’ minor child. Judgment affirmed. | Tucker | Greene |
7/3/2025
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7/3/2025
| 2025-Ohio-2355 |
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State v. Oatneal
| 2024-CA-73 | After an alleged domestic violence incident, appellant-boyfriend called the police, stating there was no emergency but he wanted to file a restraining order; this prompted a police officer’s response to girlfriend’s location in a nearby parking lot. The police officer’s encounter with girlfriend was recorded on his body camera and used at appellant’s trial for domestic violence; girlfriend did not testify at trial, and there was no other evidence of her version of events. The admission of body camera footage of girlfriend’s interview with the police officer violated appellant’s rights under the confrontation clause. There was no ongoing emergency, the statements were testimonial in nature, and they did not qualify as excited utterances. As such, there was insufficient evidence to support appellant’s conviction. Judgment vacated. | Huffman | Greene |
7/3/2025
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7/3/2025
| 2025-Ohio-2357 |
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In re Adoption of D.X.B.
| 30404 | The trial court did not err when it held that mother’s consent to her child’s adoption was not required. Mother did not have more than de minimis contact with the child or provide maintenance and support in the year prior to the filing of the adoption petition. Judgment affirmed. | Epley | Montgomery |
7/3/2025
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7/3/2025
| 2025-Ohio-2354 |
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Martin v. Becker
| 30323 | Contractor-appellant brought suit on his mechanic’s lien for work performed on a condominium, and appellees counterclaimed for breach of contract, negligence, unsafe conditions, and violations of the Consumer Sales Practices Act. The trial court granted summary judgment to appellees on all counterclaims and, later, determined damages for the counterclaims. On appeal, contractor could not raise issues related to the grant of summary judgment on his claims, because he did not appeal the trial court’s final appealable order resolving those claims. Appellees had standing to assert the counterclaims, notwithstanding the sale of the condominium. The trial court’s failure to consider contractor’s motion for reconsideration of the interlocutory grant of summary judgment on the counterclaims, based on the mistaken belief that it lacked jurisdiction to do so, requires remand. Judgment reversed and remanded. | Epley | Montgomery |
7/3/2025
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7/3/2025
| 2025-Ohio-2356 |
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Stueve v. Stueve
| 30331 | Appellant failed to cite any evidence in the record establishing that the trial court’s qualified domestic relations order was inconsistent with or modified the terms of the divorce decree. Judgment affirmed. | Lewis | Montgomery |
7/3/2025
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7/3/2025
| 2025-Ohio-2359 |
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Calicoat v. Conner
| 30365 | The trial court reasonably concluded that a landlord was not entitled to damages from a former tenant after she vacated a rental property that he owned. The trial court did not abuse its discretion in adopting the magistrate’s conclusions that the landlord’s testimony lacked credibility and that the alleged damage had not been established by the weight of the evidence. Judgment affirmed. | Huffman | Montgomery |
6/27/2025
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6/27/2025
| 2025-Ohio-2252 |
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State v. McCain
| 30410 | The sentence imposed by the trial court fell within the statutory range, and the court considered the purposes and principles of sentencing and the seriousness and recidivism factors set forth in R.C. 2929.11 and R.C. 2929.12. The court was not required to make any specific findings or provide its reasons for the sentence. Judgment affirmed. | Huffman | Montgomery |
6/27/2025
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6/27/2025
| 2025-Ohio-2254 |
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State v. Parker
| 30353 | The trial court did not err in overruling appellant’s motion to terminate her commitment following a finding that she was incompetent to stand trial. The maximum prison term appellant could have received if she had been convicted of the most serious offense charged had not yet expired under R.C. 2945.401(J)(1)(b). Judgment affirmed. | Lewis | Montgomery |
6/27/2025
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6/27/2025
| 2025-Ohio-2255 |
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State v. Halderman
| 2025-CA-5 | Neither Crim.R. 11(C)(2) nor Crim.R. 11(D) applied to appellant’s guilty plea to a first-degree misdemeanor charge of unlawful sexual conduct with a minor. Therefore, any failure by the trial court to comply with those provisions did not render his plea involuntary or otherwise invalidate it. Judgment affirmed. | Tucker | Greene |
6/27/2025
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6/27/2025
| 2025-Ohio-2253 |
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State v. Weaver
| 2024-CA-53 | The trial court did not err in overruling appellant’s motion to suppress his statements to state agents and evidence of his possession of a firearm following an administrative inspection of a club at which appellant was providing security services. The encounter was consensual, and the firearm was in plain view. Even if a brief detention occurred, the investigating agents had reasonable suspicion that criminal activity was afoot. Appellant’s conviction for having weapons under disability was supported by sufficient evidence of his prior conviction of a felony offense of violence. Judgment affirmed. | Hanseman | Clark |
6/27/2025
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6/27/2025
| 2025-Ohio-2256 |
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Becraft v. Snyder
| 2025-CA-10 | The juvenile court did not abuse its discretion in terminating the parties’ shared parenting plan, designating mother as the legal custodian and residential parent of the parties’ children, and awarding father parenting time at mother’s discretion. The juvenile court did not err in ordering father to comply with the guardian ad litem’s recommendations, as represented in mother’s testimony, that father comply with sentencing requirements in a criminal matter, address his alcohol issues, and maintain his mental health. The court did not abuse its discretion in allowing father’s counsel to withdraw on the day of the hearing. Judgment affirmed. | Huffman | Clark |
6/20/2025
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6/20/2025
| 2025-Ohio-2164 |
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State v. Thompson
| 2024-CA-40 | The trial court did not clearly err when it overruled appellant’s objection to the State’s use of a peremptory challenge on an African-American prospective juror. Appellant’s convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. The trial court did not commit plain error in providing a jury instruction requested by the State that was a correct statement of law, relevant to the case, and supported by the evidence. The trial court did not err in refusing to merge two felonious assault offenses and an improper discharge of a firearm offense, because the offenses were of dissimilar import or significance. The trial court’s findings in support of consecutive sentences were not clearly and convincingly not supported by the record. The trial court erred by failing to advise appellant of and properly calculate his jail-time credit. Judgment affirmed in part, reversed in part, and remanded for proper imposition of jail-time credit. | Lewis | Clark |
6/20/2025
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6/20/2025
| 2025-Ohio-2168 |
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State v. Webster
| 2024-CA-56 | The trial court’s imposition of two 12-month sentences, to be served consecutively, was not contrary to law and not appealable where the parties had agreed to a 24-month sentence for appellant’s two fourth-degree felonies. Judgment affirmed. | Epley | Clark |
6/20/2025
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6/20/2025
| 2025-Ohio-2169 |
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State v. Wood
| 2024-CA-49 | The trial court did not abuse its discretion by denying appellant’s petition for postconviction relief without an evidentiary hearing, because appellant did not meet his initial burden of demonstrating that there were substantive grounds for relief. The trial court did not abuse its discretion by overruling appellant’s motion for leave to move for a new trial, because appellant failed to demonstrate, by clear and convincing evidence, that he had been unavoidably prevented from discovering the alleged newly discovered evidence. The trial court’s consideration of the State’s untimely responses to appellant’s petition and motion for leave was harmless error. The trial court had no duty to notify the public defender or to appoint counsel when the court found that appellant was not entitled to an evidentiary hearing on his petition. Judgment affirmed. | Lewis | Clark |
6/20/2025
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6/20/2025
| 2025-Ohio-2170 |
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State v. Duran
| 2024-CA-41 | Appellant’s convictions for felonious assault and escape were not against the manifest weight of the evidence; the jury was free to credit the testimony of the State’s experts over the defense expert in determining that appellant was not insane at the time of those crimes. Appellant’s argument that he did not actually commit an attempted kidnapping is foreclosed by his not guilty by reason of insanity plea to that offense, which was an affirmative defense that necessarily admitted the elements of the crime. Finally, appellant’s sentence was not contrary to law. Judgment affirmed. | Epley | Greene |
6/20/2025
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6/20/2025
| 2025-Ohio-2165 |
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