Case Citator › State v. Mathis

State v. Mathis

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

Superseded by statute
Court
Supreme Court of Ohio
Citation
109 Ohio St. 3d 54
Decided
Confirmed treatments
1
Flagged citations read
28 of 28
Citing cases (total)
28
Treatment dates
2014
Superseded by statute
A reviewed court treats this case as superseded by later legislation. State v. Mathis's rule that judges need no findings before imposing consecutive prison terms was superseded by Ohio's 2011 amendment to R.C. 2929.14.
More on how this was screened

The Ohio Supreme Court explained the new requirement in State v. Bonnell, listed below. State v. Moore cited Mathis for a court's discretion to select a term within the statutory range while applying the restored findings requirement for consecutive terms. All 28 flagged citations have been read; the amendment did not displace Mathis's other sentencing guidance.

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.

28 later cases cite State v. Mathis; 28 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.

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Treatments

Superseded by statute

  • Ohio's 2011 amendment restored required findings for consecutive sentences, ending the no-findings rule Mathis had stated for the post-Foster statutory period.

    State v. Bonnell · Supreme Court of Ohio · filed

    In 1996, the General Assembly limited trial court discretion to impose consecutive sentences by directing courts to make statutorily enumerated findings and to give supporting reasons for doing so at the time of sentencing. ... We therefore severed the requirement of judicial fact-finding from the statute, struck the presumption in favor of concurrent sentences, and held that judges had discretion to impose consecutive sentences. ... Subsequent to Hodge, the General Assembly enacted Am.Sub.H.B. No. 86, effective September 30, 2011, reviving some of the statutory language we severed in Foster. That legislation created a statutory presumption in favor of concurrent sentences and further directed courts to make statutorily enumerated findings prior to imposing consecutive sentences, but it did not require courts to give reasons in support of its findings.
    Read the full opinion on CourtListener →

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