Case Citator › State v. Edmonson

State v. Edmonson

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

Abrogated
Court
Supreme Court of Ohio
Citation
86 Ohio St. 3d 324
Decided
Confirmed treatments
1
Flagged citations read
96 of 96
Citing cases (total)
1,795
Treatment dates
2006
Abrogated
A reviewed court treats this case as abrogated by later authority. State v. Edmonson has been abrogated: all 96 flagged citations have been read, and the confirmed treatment is listed below. State v. Foster held that the statutory judicial-factfinding requirement recognized in Edmonson for imposing a maximum prison term violated Blakely v. Washington, then severed the provision so a sentencing court could impose any term within the basic felony range without those findings.
More on how this was screened

Later lower courts that report or apply Foster identify Foster as the treating authority and do not create duplicate treatments. The other reviewed opinions followed Edmonson while its rule controlled, rejected requests to revisit it, or used nearby adverse language for other cases and statutory provisions.

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.

1,795 later cases cite State v. Edmonson; 96 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. Edmonson?

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

Abrogated

  • The Ohio Supreme Court abrogated Edmonson's requirement of judicial factfinding before a maximum prison sentence by holding the governing statute unconstitutional under Blakely and severing it.

    State v. Foster · Supreme Court of Ohio · filed

    Although this statute does not use the word “findings,” our holdings in State v. Edmonson, 86 Ohio St.3d at 329, 715 N.E.2d 131, and State v. Evans, 102 Ohio St.3d 240, 2004-Ohio-2659, 809 N.E.2d 11, recognize that R.C. 2929.14(C) is mandatory and prohibits maximum sentences unless the required 'findings of fact are made beforehand. … We have consistently held that R.C. 2929.14(C) requires that specific findings be made before a maximum sentence is authorized. Evans, 102 Ohio St.3d 240, 2004-Ohio-2659, 809 N.E.2d 11, at ¶ 15; Edmonson, 86 Ohio St.3d at 325, 715 N.E.2d 131. As it stands, R.C. 2929.14(C) creates a presumption to be overcome only by judicial fact-finding. It does not comply with Blakely. … These sections are severed and excised in their entirety, as is R.C. 2929.14(C), which requires judicial fact-finding for maximum prison terms, and 2929.14(E)(4), which requires judicial findings for consecutive terms.
    Read the full opinion on CourtListener →

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