State v. Hinds

Citations

• 2026 Ohio 2278

Syllabus

CRIM.R. 3(B) — CHARGING DOCUMENT — UNIFORM TRAFFIC CITATION ¬— R.C. TITLE 29 OFFENSE — SUBJECT-MATTER JURISDICTION — APP.R. 26 — REOPENED APPEAL — INEFFECTIVE ASSISTANCE OF APPELLATE COUNSEL: Where Crim.R. 3(B) clearly and unambiguously states that a uniform traffic citation does not constitute a valid complaint for R.C. Title 29 violations, and appellant was charged with failing to comply with the order or signal of a police officer under R.C. 2921.331(A), a R.C. Title 29 offense, by a uniform traffic citation, the trial court lacked subject-matter jurisdiction. Defendant-appellant received the ineffective assistance of appellate counsel where, had appellant's counsel raised the jurisdictional issue in the direct appeal, there would have been a different outcome as appellant's conviction would have been vacated because the trial court lacked subject-matter jurisdiction.