State v. Saxon
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The confirmed treatment listed below declines to extend Saxon's separate sentence rule to the question of when an appeal may be taken; other citing opinions apply its sentencing or res judicata rules.
67 citations to State v. Saxon 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. Saxon?
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
Limited
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The court held that Saxon's rule requiring a separate sentence for each offense does not make each conviction immediately appealable while other charges in the case remain unresolved.
State v. Goodwin · Court of Appeals of Ohio, Ninth Appellate District · filed
In Saxon, the Supreme Court rejected the "sentencing package" doctrine, pursuant to which a court considers the sanctions imposed on a defendant for multiple offenses prosecuted together as components of a "single, comprehensive sentencing plan." Saxon at ¶ 5. It held that "a judge sentencing a defendant pursuant to Ohio law must consider each offense individually and impose a separate sentence for each offense."Id. at ¶ 9. It did not consider the question presented by this case: whether a trial court's failure to dispose of any of the charges against a defendant in a single case renders its judgment non-final in regard to all the charges. The Supreme Court's determination that each charge must be considered separately for purposes of imposing sentence does not mean that the defendant's conviction on *Page 10 each charge becomes appealable immediately upon imposition of sentence on that particular charge, requiring the defendant to file separate appeals from each conviction.
Read the full opinion on CourtListener →
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