107 Ohio App. 3d 51 - State v. Messer’s Empirical Analysis
1995
Citation profile
82 state decisions
How this case has been cited
Cited by 82 later decisions — most recently September 2025 · most notably 184 Ohio App. 3d 675 - State v. Pilgrim (2009), 125 Ohio App. 3d 103 - State v. Blonski (1997)
82 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 State v. Dehass · State v. Maurer · State v. Awan · State v. Wolery · 36 Ohio App. 3d 147 - State v. Blevins
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Constructive possession exists when an individual exercises dominion and control over an object, even though that object may not be within his immediate physical possession.”
12 later decisions quote this exact passage“"Failure to raise an apparent constitutional claim at trial operates as a waiver of that claim. State v. Awan (1986), 22 Ohio St.3d 120 , 123 , 202-203 . Although appellate courts have the discretion to review claims when they are not raised below, that discretion ordinarily is not exercised where the right to be vindicated was in existence prior to or at the time of trial." Id. at 58.”
2 later decisions quote this exact passage“Id. at 58. {¶ 7} Defendant has waived his right to assert the constitutional claims set forth in this assignment of error. Moreover, as we noted in Messer , a defendant's *Page 4 claim that an added term of incarceration for the firearm specification violates the constitutional guarantee against double jeopardy found in the Fifth and Fourteenth Amendments to the United States Constitution is without merit”
1 later decision quote this exact passage
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.