State v. Ruediger

2025 Ohio 4370
CourtOhio Court of Appeals
DecidedSeptember 17, 2025
Docket112830
StatusPublished

This text of 2025 Ohio 4370 (State v. Ruediger) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Ruediger, 2025 Ohio 4370 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Ruediger, 2025-Ohio-4370.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 112830 v. :

JOHN RUEDIGER, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: APPLICATION DENIED RELEASED AND JOURNALIZED: September 17, 2025

Cuyahoga County Court of Common Pleas Case No. CR-21-659443-A Application for Reopening Motion No. 580381

Appearances:

John Ruediger, pro se.

LISA B. FORBES, J.:

John Ruediger (“Ruediger” or “Appellant”) filed a timely

App.R. 26(B) application for reopening, attempting to reopen the appellate

judgment rendered in State v. Ruediger, 2024-Ohio-1975 (8th Dist.), which

affirmed his conviction for the offense of disseminating matter harmful to juveniles (R.C. 2907.323(A)(1)), with a forfeiture specification (R.C. 2941.141). For the

reasons set forth below, we decline to reopen Ruediger’s appeal.

I. Standard of Review Applicable to an App.R. 26(B) Application for Reopening

App.R. 26(B) provides a means of asserting a claim of ineffective

assistance of appellate counsel. It provides for a two-stage process where an

appellant must first make a threshold showing that appellate counsel was ineffective

on appeal. State v. Leyh, 2022-Ohio-292, ¶ 18-19. The ineffectiveness of appellate

counsel is judged using the same standard that applies to claims of ineffective

assistance of trial counsel announced in Strickland v. Washington, 466 U.S. 668

(1984). Under this standard, “an applicant must show that (1) appellate counsel’s

performance was objectively unreasonable, . . . and (2) there is ‘a reasonable

probability that, but for counsel’s unprofessional errors, the result of the proceeding

would have been different.’” Leyh at ¶ 18, quoting Strickland at 687. That is, even

if Ruediger establishes that his appellate counsel’s performance was objectively

unreasonable, he must also establish that he was prejudiced by showing that, but for

the unreasonable error, there exists a reasonable probability that the results of his

appeal would have been different. Reasonable probability, regarding an application

for reopening, is defined as a probability sufficient to undermine confidence in the

outcome of the appeal. State v. May, 2012-Ohio-5504, ¶ 5 (8th Dist.).

“The burden is on the applicant to demonstrate a ‘genuine issue’ as to

whether there is a ‘colorable claim’ of ineffective assistance of appellate counsel.”

Leyh at ¶ 21, quoting State v. Spivey, 84 Ohio St.3d 24, 25 (1998). If the applicant makes these showings, then the application shall be granted and the appeal

reopened. Id. at ¶ 21, citing App.R. 26(B)(5).

II. Ruediger’s Thirteen Proposed Assignments of Error Fail to Demonstrate a Genuine Issue as to Whether He Has a Colorable Claim for Ineffective Assistance of Appellate Counsel

Ruediger argues that thirteen proposed assignments of error were not

considered on appeal due to appellate counsel’s ineffectiveness. We disagree.

The mere recitation of assignments of error, without the presentation

of legal analysis, an explanation of how appellate counsel’s performance on appeal

was deficient, and how Ruediger was prejudiced, does not support the reopening of

Ruediger’s original appeal under App.R. 26(B). See State v. Clark, 2025-Ohio-2126,

¶ 14 (8th Dist.); State v. Abraham, 2025-Ohio-1446, ¶ 18 (8th Dist.) (a laundry list

of complaints regarding an applicant’s trial does not meet the requirements to grant

an App.R. 26(B) application for reopening). See also State v. Pennington, 2025-

Ohio-1445, ¶ 14 (8th Dist.); State v. Townsend, 2022-Ohio-4398 ¶ 7 (8th Dist.);

State v. Gaughan, 2009-Ohio-2702, ¶ 5 (8th Dist.).

Ruediger did not provide any legal analysis or argument regarding the

prejudice prong of the Strickland test for any of his thirteen proposed assignments

of error. As a result, he failed to demonstrate the existence of a genuine issue as to

whether he has a colorable claim for ineffective assistance of appellate counsel.

Moreover, an independent review of each of Ruediger’s thirteen

proposed assignments of error fails to reveal any errors that would have resulted in

a reasonable probability of a different outcome on appeal. A. Proposed Assignment of Error No. 1 — “The trial court erred when it allowed a trial to commence after an improper arrest of the Appellant.”

In his first proposed assignment of error, Ruediger asserts that the

police officers who arrested him did not have a warrant or probable cause, never told

him he was under arrest, and did not allow him to make any phone calls or to contact

a lawyer.

In his direct appeal, in his first assignment of error, Ruediger

challenged the trial court’s denial of a motion to suppress, arguing, among other

things, that he was not allowed to make any phone calls or contact counsel after he

was arrested. Ruediger, 2024-Ohio-1975, at ¶ 45-64 (8th Dist.). This court rejected

both arguments. Consequently, the record does not support his claim that these

issues were not considered on direct appeal. See App.R. 26(B)(2)(c) (A successful

application for reopening must assert proposed assignments of error that “were not

considered on the merits in the case . . . or that were considered on an incomplete

record because of appellate counsel’s deficient representation.”). Moreover, res

judicata bars the relitigation of an issue that was previously addressed on appeal,

even if cast in a slightly different form. State v. Barnes, 2020-Ohio-4988, ¶ 13 (8th

Dist.).

Furthermore, a warrantless arrest based upon probable cause does

not violate the Fourth Amendment to the United States Constitution. State v.

Brown, 2007-Ohio-4837, ¶ 66, citing United States v. Watson, 423 U.S. 411, 417

(1976). Here, the record demonstrates that the police possessed probable cause to arrest Ruediger based upon, among other things, the electronic communications

between K.V. and Ruediger found on K.V.’s phone.1

Ruediger has not demonstrated a genuine issue as to whether there is

a colorable claim that his appellate counsel was objectively unreasonable for failing

to raise Ruediger’s his first proposed assignment of error.

B. Proposed Assignment of Error No. 2 — “The Appellant was denied a fair trial when [police] refused to explore knowingly exculpatory evidence located on K.V.’s phone.”

Ruediger argues that the police failed to explore exculpatory evidence

contained in the victim’s cell phone that would have demonstrated that K.V. never

told Ruediger his true age and lied at the time of trial. Ruediger claims that if K.V.’s

profile on an adults-only dating website had been inspected, “we’d see K.V.’s texts

with [Appellant], an adult photo he used in his profile and him telling [Appellant]

he was an adult.”

On appeal this court analyzed the evidence presented at trial,

including K.V.’s own testimony that he had a Grindr account which he described as

a dating website that is “mainly used for hookups.” Ruediger, 2024-Ohio-1975, at

¶ 21 (8th Dist.). K.V. acknowledged that “‘[y]ou had to be older than 18’ to set up a

profile on Grindr. According to K.V. he lied about his age, and his Grindr profile

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Related

United States v. Watson
423 U.S. 411 (Supreme Court, 1975)
Smith v. Phillips
455 U.S. 209 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Cleveland v. Schmidt
2013 Ohio 1547 (Ohio Court of Appeals, 2013)
State v. May
2012 Ohio 5504 (Ohio Court of Appeals, 2012)
State v. Tate, Unpublished Decision (3-2-2004)
2004 Ohio 973 (Ohio Court of Appeals, 2004)
State v. Logan, 88472 (4-22-2008)
2008 Ohio 1934 (Ohio Court of Appeals, 2008)
State v. Wilks (Slip Opinion)
2018 Ohio 1562 (Ohio Supreme Court, 2018)
State v. Leyh (Slip Opinion)
2022 Ohio 292 (Ohio Supreme Court, 2022)
State v. Virostek
2022 Ohio 1397 (Ohio Court of Appeals, 2022)
State v. Stephens
263 N.E.2d 773 (Ohio Supreme Court, 1970)
State v. Smith
470 N.E.2d 883 (Ohio Supreme Court, 1984)
State v. Manross
532 N.E.2d 735 (Ohio Supreme Court, 1988)
State v. Lott
555 N.E.2d 293 (Ohio Supreme Court, 1990)
State v. Keenan
613 N.E.2d 203 (Ohio Supreme Court, 1993)
State v. Ballew
667 N.E.2d 369 (Ohio Supreme Court, 1996)
State v. Gillard
679 N.E.2d 276 (Ohio Supreme Court, 1997)
State v. White
82 Ohio St. 3d 16 (Ohio Supreme Court, 1998)
State v. Spivey
701 N.E.2d 696 (Ohio Supreme Court, 1998)
State v. Townsend
2022 Ohio 4398 (Ohio Court of Appeals, 2022)

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Bluebook (online)
2025 Ohio 4370, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-ruediger-ohioctapp-2025.