Case Citator › State v. Baker

State v. Baker

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

Overruled in part
Court
Supreme Court of Ohio
Citation
119 Ohio St. 3d 197
Decided
Confirmed treatments
2
Flagged citations read
48 of 48
Citing cases (total)
48
Treatment dates
2011
Overruled in part
A reviewed court has overruled part of this case’s holding. State v. Baker was modified in part on what makes a criminal judgment final for appeal. In State v. Lester, the Supreme Court of Ohio held that a judgment need not state the manner of conviction to be final, though the defendant remains entitled to a corrected entry stating it.
More on how this was screened

Baker's ruling that the entry need not recite the arraignment plea remains intact. All 48 flagged citations have been read; the 2 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.

48 later cases cite State v. Baker; 48 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. Baker?

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 modified Baker's finality rule: a judgment can be final for appeal without stating how the defendant was convicted.

    State v. Lester · Supreme Court of Ohio · filed

    Nevertheless, to the extent that Baker implies, or has been interpreted to require, that more than the fact of conviction and the substantive provisions of Crim.R. 32(C) must be set out in the judgment entry of conviction before it becomes a final order, we modify the holding in Baker. We hold that a judgment of conviction is a final order subject to appeal under R.C. 2505.02 when the judgment entry sets forth (1) the fact of the conviction, (2) the sentence, (3) the judge’s signature, and (4) the time stamp indicating the entry upon the journal by the clerk.
    Read the full opinion on CourtListener →

Limited

  • The Fifth District declined to extend Baker's judgment-entry ruling to give a defendant a second appeal of trial errors after a corrected sentencing entry.

    State v. Harris · Court of Appeals of Ohio, Fifth Appellate District · filed

    Appellant was then resentenced on March 26, 2010, to include the language that he was convicted by a jury and now appeals from that resentencing; however, he does not limit his arguments to the resentencing with respect to the conviction by a jury. Instead he seeks to relitigate prior substantive claims as well as raise new claims. We do not find this to be the intent of the Supreme Court in Baker.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads State v. Baker and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace