State v. Wilson

In this appeal we analyze how the General Assembly contemporaneously effects multiple, unrelated amendments to a single statutory section while complying with Section 15(D), Article II of the Ohio Constitution, requiring that “the section or sections amended shall be repealed.”

In May 1994, the General Assembly enacted a new law making assaults on law enforcement officers a felony.2 This new law amended R.C. 2903.13. Two days later, the General Assembly passed another Act changing terminology used throughout the Revised Code from “penal or reformatory institution” to “correctional…