Case Citator › State v. Williams

State v. Williams

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Supreme Court of Ohio
Citation
148 Ohio St.3d 403
Decided
Confirmed treatments
2
Flagged citations read
30 of 30
Citing cases (total)
30
Treatment dates
2020
Overruled in part
A reviewed court has overruled part of this case’s holding. State v. Williams was overruled in part on whether separate sentences for allied offenses are void. All 30 flagged citations have been read.
More on how this was screened

The Supreme Court of Ohio held in State v. Henderson that a sentencing error by a court with jurisdiction makes the sentence voidable, and State ex rel. Romine v. McIntosh expressly said Williams's void-sentence holding is no longer good law. The rule against imposing separate sentences for offenses already found to merge continues to be applied. The two confirmed treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

30 later cases cite State v. Williams; 30 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on State v. Williams?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court of Ohio overruled Williams's rule that separate sentences for allied offenses are void and open to collateral attack.

    State v. Henderson · Supreme Court of Ohio · filed

    State v. Williams, 148 Ohio St.3d 403, 2016-Ohio-7658, 71 N.E.3d 234, ¶ 28 (imposition of separate sentences for allied offenses rendered the sentences void). ... To that end, we realign our precedent with the traditional understanding of what constitutes a void judgment. When our prior cases conflict with this traditional understanding, we must overrule them. A judgment or sentence is void only if it is rendered by a court that lacks subject-matter jurisdiction over the case or personal jurisdiction over the defendant. If the court has jurisdiction over the case and the person, any error in the court’s exercise of that jurisdiction is voidable.
    Read the full opinion on CourtListener →

  • The Supreme Court of Ohio confirmed that Williams's void-sentence holding for allied offenses is no longer good law and requires a direct appeal to correct the error.

    State ex rel. Romine v. McIntosh · Supreme Court of Ohio · filed

    However, that aspect of Williams is no longer good law. Instead, “when a specific action is within a court’s subject-matter jurisdiction, any error in the exercise of that jurisdiction renders the judgment voidable, not void.” Harper, ___ Ohio St.3d ___, 2020-Ohio-2913, ___ N.E.3d ___, at ¶ 26; see also Henderson at ¶ 27. The imposition of compound sentences for allied offenses is an error in the exercise of jurisdiction, to be challenged at sentencing and remedied on direct appeal.
    Read the full opinion on CourtListener →

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