State v. Adams
- Court
- Ohio Supreme Court
- Decided
- May 7, 1980
- Docket
- No. 79-530
- Status
- Published
- Jurisdiction
- Ohio
Cited 3,804 timesNo negative treatment found in this library
What later courts said
- holding that a trial court’s failure to specifically charge the jury on every element of an offense is not per se plain error, but could result in plain error if the failure substantially prejudiced the defendant — State v. Colston (2020)
- holding that a trial court’s failure to specifically charge the jury on every element of an offense is not per se plain error, but could result in plain error if the failure substantially prejudiced the defendant — State v. Woods (2022)
- holding that a trial court’s failure to specifically charge the jury on every element of an offense is not per se plain error, but could result in plain error if the failure substantially prejudiced the defendant — State v. Kerns (2021)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
Sweeney, J.
The Court of Appeals found plain and reversible error in the trial court’s failure to instruct the jury on the degree of mental culpability requisite to a finding of criminal liability under the endangering children statute (R. C. 2919.22).
R. C. 2919.22(B)(2),[1] as submitted to the jury for its con [*153] sideration, does not “specify any degree of culpability” nor does it “plainly indicate] a purpose to impose strict criminal liability for the conduct described in such section.” R. C. 2901.21(B). Recklessness therefore is sufficient culpability to commit the offense. The Court of Appeals correctly held that prior to finding a defendant guilty of violating R. C. 2919.22(B)(2), the state must prove recklessness on the part of the defendant as defined in R. C. 2901.22(C). The state has the burden of establishing all material elements of a crime by proof beyond a reasonable doubt. Mullaney v. Wilbur (1975), 421 U. S. 684.
Cite this
State v. Adams, 62 Ohio St. 2d 151 (1980)Read the full opinion
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