State v. Lash

Summary

The Supreme Court of Ohio held that a trial court's order rejecting an application for postconviction DNA testing satisfies R.C. 2953.73(D)'s "reasons" requirement when it identifies a statutory reason for its decision, and that no further findings or analysis is required. Reading the undefined term "reasons" according to its plain and ordinary meaning, and contrasting R.C. 2953.21(D), which expressly requires findings of fact and conclusions of law, the court concluded the trial court complied by stating that DNA testing would not be outcome determinative, and declared prior appellate decisions requiring more no longer good law. It reversed the Eighth District's judgment and remanded for abuse-of-discretion review of the rejection. Brunner, J., dissented, contending the statute's "as applied" clause requires courts to actually analyze the statutory criteria rather than merely recite a reason.