100 Ohio App. 3d 90 - State v. Combs’s Empirical Analysis
1994
Citation profile
23 federal appellate · 189 state decisions
How this case has been cited
Cited by 232 later decisions — most recently July 2025 · most notably Byrd v. Collins (2000), Combs v. Coyle (2000)
23 federal appellate · 189 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Strickland v. Washington · State v. Bradley · Lockhart v. Fretwell · State v. Perry · State v. Ishmail
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 232 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the evidence must show that the petitioner could not have appealed the constitutional claim based on the information in the original trial record.”
3 later decisions quote this exact passage · from the majority“'[W]hen, as here, counsel has presented a meaningful concept of mitigation, the existence of alternate or additional mitigation theories does not establish ineffective assistance.' State v. Combs , 100 Ohio App.3d 90 , 105, 652 N.E.2d 205 , 214 (1994).”
2 later decisions quote this exact passage · from the majority“A postconviction petition does not show ineffective assistance merely because it presents a new expert opinion that is different from the theory used at trial.”
2 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.