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State v. Quarels
| C-250470, C-250471 | SECURITY SERVICES — R.C. 4749.13 — MANIFEST WEIGHT — SUFFICIENCY OF THE EVIDENCE – EQUAL PROTECTION: The trial court did not err in denying defendant’s motions to dismiss his charges for engaging in the business of security services without a license, as the security services licensing scheme is constitutional as it is rationally related to the government’s legitimate interest in public safety. Defendant’s convictions for engaging in the business of security services without a license were not against the manifest weight of the evidence and were supported by sufficient evidence where defendant wore security-type apparel outside two bars, was captured on body-worn camera footage engaging in security services, admitted to owning a security services company, and admitted to being paid in cash to provide security services. | Kinsley | Hamilton |
6/24/2026
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6/24/2026
| 2026-Ohio-2394 |
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State v. King
| C-250406 | R.C. 2945.71 – SPEEDY TRIAL: The trial court did not err in dismissing defendant’s charges after the State failed to bring defendant to trial within the 90-day statutory period. | Nestor | Hamilton |
6/24/2026
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6/24/2026
| 2026-Ohio-2393 |
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State v. Pitts
| C-250584 | ASSAULT — SELF-DEFENSE — MANIFEST WEIGHT: The trial court did not err in finding that defendant was at fault for creating the situation giving rise to the altercation where the testimony established defendant was the initial aggressor who advanced upon and injured the victim and the court found the victim’s testimony to be credible. | Zayas | Hamilton |
6/18/2026
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6/18/2026
| 2026-Ohio-2306 |
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State v. Madaris
| C-250396 | CONSTITUTIONAL LAW/CRIMINAL — SEARCH AND SEIZURE — SEARCH WARRANT — MOTION TO SUPPRESS — GOOD-FAITH EXCEPTION — EVIDENCE — CONSTRUCTIVE POSSESSION — POSSESSION OF DRUGS — SUFFICIENCY — MANIFEST WEIGHT— INEFFECTIVE ASSISTANCE OF COUNSEL: The trial court did not err in overruling defendant’s motion to suppress evidence found in the residence pursuant to the search warrant because the affidavit provided a minimally sufficient nexus between the offenses under investigation and the need to search the home, and the officers acted in good-faith reliance on the warrant. The trial court did not err by admitting two text messages referencing a drug transaction sent to defendant during the execution of the search warrant because the evidence directly proved that defendant had the intent and knowledge to sell the drugs he possessed on that day, a necessary element to establish the charged offenses. Any error by the trial court in admitting two text messages referencing drug transactions sent close in time to the charged offense was harmless because defendant was acquitted of the trafficking charges. Defendant’s convictions for possession of a fentanyl-related compound and aggravated possession of drugs were supported by sufficient evidence and not against the weight of the evidence where the State proved defendant constructively possessed the drugs where the evidence established defendant regularly slept at the residence, he was the sole occupant of the residence when the warrant was executed, some of the drugs were found in plain view in the bedroom, he was in the bedroom when the search was initiated, his clothing and boots were in the bedroom, and text messages revealed that defendant intended to sell drugs that morning. Defendant’s trial counsel did not provide ineffective assistance of counsel because counsel’s questioning of the lead detective was trial strategy designed to undermine the credibility of the lead investigator, the investigation, and the lack of evidence of trafficking. | Zayas | Hamilton |
6/18/2026
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6/18/2026
| 2026-Ohio-2305 |
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State ex rel. Attorney General v. Hamm
| C-240137 | IMMUNITY — R.C. 3313.25(B) — COMMUNITY SCHOOLS — AUDIT REPORT — STATUTE OF LIMITATIONS — STATE AUDITOR — EXPUNGMENT — INVITED ERROR — JURY INSTRUCTIONS – LAY TESTIMONY – HARMLESS ERROR: The trial court’s denial of defendant/third-party plaintiff’s motion for judgment on the pleadings was proper because defendant/third-party plaintiff was a fiscal officer for a community school, R.C. 3313.25(B) shields treasurers of a school district board of education from liability, and defendant/third-party plaintiff was not entitled to immunity under the statute. The trial court appropriately denied defendant/third-party plaintiff’s motion for summary judgment based on defendant/third-party plaintiff’s contention that plaintiff-State’s complaint to recover misappropriated funds pursuant to an audit report were untimely and barred by R.C. 2305.07’s six-year statute of limitations because plaintiff-State is exempt from generally worded statutes of limitations like R.C. 2305.07. Issues surrounding the trial court’s denial of summary judgment based on the existence of a genuine issue of material fact regarding the validity of the audits and audits procedure are moot or harmless because evidence produced at trial confirmed the existence of a genuine issue of material fact. Defendant/third-party plaintiff invited any error and opened the door to the admission of otherwise inadmissible evidence of her expunged convictions when defendant/third-party plaintiff claimed in her opening statement that criminal charges were never pursued against her. The trial court did not abuse its discretion when it (1) rejected defendant/third-party plaintiff’s proposed jury instructions comprised of entire statutory sections, which were unclear, not concise, and incomplete; and (2) instructed the jury that defendant/third-party plaintiff had the burden of establishing a breach of an indemnification contract. Allowing lay witness testimony from an employee of the state auditor’s office that was not based on the employee’s personal observations was a harmless error where the facts recited by the employee were established in the auditor’s report, which is prima facie evidence of its contents. | Bock | Hamilton |
6/18/2026
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6/18/2026
| 2026-Ohio-2304 |
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