State v. Ball

Court of Appeals of Ohio, Fifth Appellate District, Licking County · 2024 · Evidence
EvidenceSentencingAnders appealPostrelease controlfelony sentencingcontrary to lawclear and convincingR.C. 2929.11

Facts

Ball pleaded guilty to one count of obstructing official business, a fifth-degree felony. The trial court sentenced him to one year in prison and also imposed 515 days, described as the balance of his existing postrelease-control time, to run consecutively. During the plea colloquy, the court told Ball it could impose any remaining postrelease-control time in addition to or consecutively with the new sentence, and Ball said he understood. At sentencing, Ball agreed the remaining balance was one year and five months, which the court treated as 515 days.

Issue

Whether Ball's sentence was clearly and convincingly contrary to law under R.C. 2953.08(G)(2) because the trial court imposed 515 days for the postrelease-control violation and did not expressly state that imposing that prison term terminated Ball's earlier postrelease control.

Rule

Under R.C. 2953.08(G)(2), an appellate court may modify or vacate a felony sentence only if it clearly and convincingly finds that the record does not support relevant statutory findings or that the sentence is otherwise contrary to law. A sentence is not clearly and convincingly contrary to law when the trial court considers R.C. 2929.11 and R.C. 2929.12, imposes a sentence within the statutory range, and properly imposes postrelease control. Under R.C. 2929.141(A)(1), a court may impose the balance of a defendant's remaining postrelease-control time consecutively, and imposing that prison term terminates the earlier period of postrelease control by operation of law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Columbus, Ohio, Devin Cross pleaded guilty to a fifth-degree felony. The trial judge stated on the record and in the judgment entry that she considered R.C. 2929.11 and R.C. 2929.12, reviewed a presentence investigation report, and imposed 12 months in prison.

On appeal, Devin argues only that the sentence is too harsh and should be reduced because the appellate court would have weighed the sentencing factors differently. Under the governing rule, what is the best answer?

Explanation. Under R.C. 2953.08(G)(2), the appellate court may modify or vacate only if it clearly and convincingly finds the sentence unsupported by relevant findings or otherwise contrary to law. The majority explained that a sentence is not clearly and convincingly contrary to law when the court considers R.C. 2929.11 and R.C. 2929.12, properly imposes postrelease control, and imposes a term within the permissible statutory range. Mere disagreement with the trial court's weighing does not supply a basis for reversal. (Derived from State v. Ball (n.d.).)