State v. Woods, 2014 Ohio 296

Woods sought to reopen his appellate judgment in State v. Woods, 8th Dist. Cuyahoga No. 82789, 2004-Ohio-2700.
The underlying convictions were for rape, gross sexual imposition, and kidnapping.
The trial court denied his application for reopening; Woods appeals the denial to the court of appeals.
The court denied the reopening application on procedural grounds, not on merits.
Specifically, Woods failed to comply with the ten-page limit of App.R. 26(B)(4) and filed beyond the 90-day deadline, without showing good cause.
Ignorance of the law and limited access to materials were held not to constitute good cause for untimely filing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Woods' App.R. 26(B) application complied with page limits	Woods exceeded the ten-page limit.	Woods' delay and length violate rule limits for reopening.	Denied for exceeding page limit.
Whether Woods' App.R. 26(B) application was timely	Woods filed within the 90-day window after journalization.	Woods filed more than 90 days after journalization without good cause.	Denied due to untimeliness and lack of good cause.
Whether good cause existed to excuse untimely filing	N/A or Woods contends some excusable reason.	No sound good-cause justification was offered; ignorance of law not sufficient.	Denied; no good cause shown.

State v. Gumm, 103 Ohio St.3d 162 (2004-Ohio-4755) (strict enforcement of 90-day deadline; timely filing essential)
LaMar v. State, 102 Ohio St.3d 467 (2004-Ohio-3976) (timeliness and good cause requirements for reopening)
State v. Cooey, 73 Ohio St.3d 411 (1995-Ohio-252) (limits and standards for reopening applications)
State v. Reddick, 72 Ohio St.3d 88 (1995-Ohio-249) (reopening requirements and timeliness considerations)
State v. Winstead, 74 Ohio St.3d 277 (1996-Ohio-52) (90-day deadline applied to reopening)
Logan v. Zimmerman Brush Co., 455 U.S. 422 (1982) (federal due-process approach to triggering adjudication rights; supports deadline enforcement)