OH5: Ohio recognizes Groh incorporation by reference for particularity

Ohio recognizes Groh incorporation by reference for particularity. State v. Starcher, 2026-Ohio-15, 2026 Ohio App. LEXIS 11 (5th Dist. Jan. 6, 2026).

In a civil case, the reference to Fourth Amendment was a typo for Fourteenth. It will be considered the Fourteenth. Eleveld v. Ill. Dep’t of Children & Family Servs., 2026 U.S. Dist. LEXIS 659 (N.D. Ill. Jan. 5, 2026).*

The federal suit over plaintiff’s November 2025 arrest is barred by Younger. If there’s an excessive force complaint, file it separately. Ellis v. Rivaslariosa, 2026 U.S. Dist. LEXIS 727 (S.D. Fla. Jan. 5, 2026).*

The dashcam came on after the traffic violation so it’s not shown on the video, and the video can’t be relied upon to discount the USMJ’s findings. United States v. Seakor, 2026 U.S. Dist. LEXIS 879 (D.S.D. Jan. 2, 2026).*

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