12/23/2022

Case Caption Case No. Topics and Issues Author Citation
State v. Burns 2020-1126Criminal law—Juvenile law—R.C. 2152.12—R.C. 2151.23—Juvenile court determined that act alleged in juvenile-court complaint was not supported by probable cause, and defendant was then indicted and convicted in adult court for same act—Conviction vacated on the authority of State v. Smith—Counts in indictment pertaining to offenses that were not charged in the juvenile-court complaint but were based on conduct included in the juvenile-court complaint were properly brought in adult court—Court of appeals’ judgment affirmed in part and reversed in part and cause remanded.Stewart, J.Slip Opinion No. 2022-Ohio-4606
State v. Gwynne 2021-1033Criminal law—Sentencing—R.C.2929.14(C)(4)—Consecutive-sentence findings are not simply threshold findings that, once made, permit any amount of consecutively stacked individual sentences—Consecutive-sentence findings must be made in consideration of the aggregate term to be imposed—Appellate review of consecutive sentences under R.C. 2953.08(G)(2) does not require an appellate court to defer to a sentencing court’s findings—Court of appeals’ judgment reversed and cause remanded.Stewart, J.Slip Opinion No. 2022-Ohio-4607
State v. Morris 2021-1158Criminal law—Trial court’s sentence of life imprisonment constitutes cruel and unusual punishment under the Eighth and Fourteenth Amendments to the United States Constitution and Article I, Section 9 of the Ohio Constitution—A trial court must separately consider the youth of a juvenile offender as a mitigating factor before imposing a life sentence—Court of appeals’ judgment reversed and cause remanded.Stewart, J.Slip Opinion No. 2022-Ohio-4609
State v. Thompson 2021-1355Appeal dismissed as having been improvidently accepted. Slip Opinion No. 2022-Ohio-4610
State v. Blackburn 2022-0536 and 2022-0688Court of appeals’ judgment affirmed on the authority of State v. Bollar. Slip Opinion No. 2022-Ohio-4612
12/23/2022 Case Announcements  Merit decisions with opinions.  
12/23/2022 Case Announcements #2  Reconsideration of prior decisions.  
State v. Ashcraft 2021-1491R.C. 2950.99(A)(2)(b)—A three-year prison term imposed under R.C. 2950.99(A)(2)(b) is to be imposed in addition to any prison term imposed under any other provision of law.Fischer, J.Slip Opinion No. 2022-Ohio-4611