78 Ohio App. 3d 784 - State v. Powell’s Empirical Analysis
1992
Citation profile
63 state decisions
How this case has been cited
Cited by 63 later decisions — most recently August 2025 · most notably 145 Ohio App. 3d 277 - State v. Kelly (2001), 107 Ohio App. 3d 723 - State v. Johnson (1995)
63 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. Lytle · State v. Hester · Roberts v. Ohio · Phung v. Waste Management, Inc.
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 63 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“clearly requires that a sentencing court shall impose a mandatory fine upon an *Page 7 offender unless (1) the offender alleges in an affidavit filed with the court prior to sentencing that the offender is indigent and unable to pay the mandatory fine, and (2) the court determines that the offender is in fact an indigent person and is unable to pay the mandatory fine.”
3 later decisions quote this exact passage“[t]here is a difference between a finding of indigency for purposes of receiving appointed legal counsel and the finding of indigency to avoid having to pay a mandatory fine.”
3 later decisions quote this exact passage““Many criminal defendants, even those who have steady income, are not able to raise sufficient funds to pay the retainer fee required by private counsel before counsel will make an initial appearance. This difference is even more evident in cases where the defendant has to utilize his financial resources to raise sufficient bond money in order to be released from jail. In contrast, the payment of a mandatory fine over a period of time is not equivalent to the immediate need for legal representation at the initiation of criminal proceedings.” Powell, 78 Ohio App.3d at 789-790 , 605 N.E.2d at 1341 .”
2 later decisions 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.