Public-domain · open source
OpenJurist

92 Ohio App. 3d 732

637 N.E.2d 80

State v. Castle

Ohio Court of Appeals

Decided January 12, 1994

Ohio Court of Appeals · decided 1994-01-12

Good law ✅— No negative treatment on recordhow we know

Decided 1994-01-12

How this case has been cited

Cited by 12 later decisions — most recently March 2025

12 state decisions

401994200020102020decided

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.

View the full empirical analysis of this case →

Baird, Judge,

¶1 concurring.

¶2 In this case, the trial court found as a fact that both Shonk and Ross received their subpoenas. The issue, then, as I see it, is whether they can be relieved from compliance by reason of a claimed impropriety in the method of serving the subpoenas.

¶3 Though Crim.R. 17(G) would seem to require service to support a finding of contempt, a provision as to what constitutes contempt seems to me to be substantive, rather than procedural, thus making this an inappropriate provision for a rule adopted under a grant of authority limited to procedural matters. I believe, however, that this case may properly be considered under more general *736 principles relating to the inherent powers of the court to require compliance of every person who has knowledge of an order of court.

¶4 I concur in the judgment.

/92/ohioapp3d/732 · .json · Public domain