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State v. Bell
| C-250533 | CRIM.R. 3 — SUBJECT-MATTER JURISDICTION — MUNICIPAL COURT JURISDICTION — COMPLAINTS — FAILURE TO DISCLOSE PERSONAL INFORMATION — R.C. 2921.29 — PUBLIC PLACE — STATUTORY INTERPRETATION — SUFFICIENCY OF THE EVIDENCE — MANIFEST WEIGHT OF THE EVIDENCE — OBSTRUCTING OFFICIAL BUSINESS — R.C. 2921.31 — DISORDERLY CONDUCT — R.C. 2917.11: The municipal court had subject-matter jurisdiction where, although the complaint failed to allege under which subsection defendant was charged, defendant had fair notice of which provision was at issue. Because a detainee in the back seat of a police cruiser is not “in a public place,” the State failed to present sufficient evidence to convict defendant of violating R.C. 2921.29. [But see DISSENT: Under the plain language of the statute, defendant was in a public place while sitting in a police cruiser parked on a public road.] Defendant’s conviction for obstructing official business was not against the manifest weight of the evidence where the evidence showed he had repeatedly screamed, yelled, and kicked the inside of a police vehicle, requiring one of the investigating officers to remain near the vehicle rather than investigate the offense. Defendant’s conviction for disorderly conduct was not against the manifest weight of the evidence where the evidence showed defendant had repeatedly and violently kicked the interior of a police vehicle, inconveniencing the investigating officers. | Crouse | Hamilton |
9/16/2026
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9/16/2026
| 2026-Ohio-3614 |
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Walker v. Fid. Invests. Inst. Operations Co., L.L.C.
| C-260088 | MOTION TO DISMISS — IMPLIED-IN-FACT CONTRACT — UNJUST ENRICHMENT — CONSTRUCTIVE FRAUD — BREACH OF FIDUCIARY DUTY — CONVERSION: The trial court appropriately dismissed plaintiff’s amended complaint because she alleged no set of facts that could establish claims for a breach of an implied contract, unjust enrichment, breach of a fiduciary duty, constructive fraud, or conversion. | Bock | Hamilton |
9/16/2026
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9/16/2026
| 2026-Ohio-3616 |
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State v. Doherty
| C-250694 | SEARCH AND SEIZURE — TERRY STOP – EVIDENCE: The trial court erred in granting defendant’s motion to suppress where the defendant’s investigatory detention and subsequent seizure of her belongings was based upon the police officers’ reasonable suspicion that defendant provided them with a false name. | Moore | Hamilton |
9/16/2026
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9/16/2026
| 2026-Ohio-3615 |
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In re L.E.S
| C-220430, C-220436 | CUSTODY — SHARED-CUSTODY AGREEMENT — WORDS AND CONDUCT — BEST INTEREST — COMPANIONSHIP TIME: The juvenile court did not abrogate “Ohio’s well-established legal framework for same-sex custody disputes” where the juvenile court applied the framework set forth by the Ohio Supreme Court in In re Mullen, 2011-Ohio-3361. The juvenile court did not err in determining that a shared-custody agreement existed regarding the two younger children where the juvenile court found that the parties shared an intent to “coparent” the children that was synonymous with an understanding that appellant parent intended to permanently relinquish some of her rights to exclusive custody of the children in favor of shared custody with appellee custodian and the juvenile court’s decision was supported by sufficient evidence and not against the manifest weight of the evidence. The juvenile court did not err in utilizing the statutory factors under R.C. 3109.04(F)(2) as guidance when determining whether shared custody was in the best interest of the children under In re Mullen, 2011-Ohio-3361, where the juvenile court was required to consider “all known factors” under In re Bonfield, 2002-Ohio-6660, and the juvenile court found that, although the factors under R.C. 3109.04(F)(2) were not directly applicable, a best-interest determination under In re Mullen “should resemble a best interest determination for shared parenting” as a shared-custody agreement is “substantially similar” to a shared-parenting agreement. The juvenile court’s determination that shared custody is in the best interest of the children was supported by sufficient evidence and not against the manifest weight of the evidence where the testimony of the parties and the guardian ad litem support the juvenile court’s findings and the juvenile court was permitted to determine the weight of the evidence. The juvenile court did not err in awarding appellee custodian companionship time with the two younger children without affording any special weight to appellant parent’s wishes where the evidence shows that appellant parent voluntarily relinquished sole custody in favor of shared custody with appellee custodian and appellant parent conceded at oral argument that the award of companionship time to appellee custodian under such an agreement was “no harm no foul.” The juvenile court did not err in declining to terminate the shared-custody agreement regarding the older child where the juvenile court found that shared custody was in the best interest of the child and this determination was supported by the record. | Zayas | Hamilton |
9/16/2026
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9/16/2026
| 2026-Ohio-3613 |
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State v. Jimenez
| C-250542 | RAPE — CONFRONTATION CLAUSE — TESTIMONIALITY — EXPERT TESTIMONY — R.C. 2907.27 — HARMLESS ERROR — DUE PROCESS — INTERPRETERS — ACCESS TO EVIDENCE — JURY WAIVER — R.C. 2945.05 — CRIM.R. 23(A) — MANIFEST WEIGHT — CREDIBILITY: The trial court erred in overruling defendant’s Confrontation Clause objection to an expert witness’s testimony regarding reported laboratory test results, where the analysts who prepared the report would have reasonably believed it would be used at a subsequent trial, and where those analysts were not subject to cross-examination. Although the admission of the laboratory test results showing that defendant and victim had tested positive for the same sexually-transmitted infection violated the Confrontation Clause, the error was harmless because, even without the improperly admitted results, the evidence of defendant’s guilt—including the credible testimony of his victim—was overwhelming. Defendant was not denied due process where defendant spoke only Spanish and his interpreter could not hear portions of the video evidence, because the factfinder had just as much trouble hearing as defendant’s interpreter and defense counsel had received the video in discovery. Even though defendant did not speak English, he failed to show that his jury waiver was invalid because (1) he had signed the English-language waiver form, consistent with R.C. 2945.05, (2) he had acknowledged in open court and through an interpreter that he had a right to a jury trial and that he wished to waive it, and (3) he offered no additional evidence to rebut the presumption of his waiver’s validity. Defendant’s convictions for rape were not against the manifest weight of the evidence where victim’s testimony specifically and credibly described both instances of rape, and where defendant could provide only highly-improbable ulterior motives to explain why victim might have lied. | Crouse | Hamilton |
9/11/2026
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9/11/2026
| 2026-Ohio-3553 |
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