Conneaut v. Fromknecht

2024 Ohio 1119
CourtOhio Court of Appeals
DecidedMarch 25, 2024
Docket2023-A-0051
StatusPublished
Cited by3 cases

This text of 2024 Ohio 1119 (Conneaut v. Fromknecht) 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
Conneaut v. Fromknecht, 2024 Ohio 1119 (Ohio Ct. App. 2024).

Opinion

[Cite as Conneaut v. Fromknecht, 2024-Ohio-1119.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT ASHTABULA COUNTY

CITY OF CONNEAUT, CASE NO. 2023-A-0051

Plaintiff-Appellee, Criminal Appeal from the - vs - Conneaut Municipal Court

CHRISTOPHER FROMKNECHT, Trial Court No. 2022 CRB 00136 C Defendant-Appellant.

OPINION

Decided: March 25, 2024 Judgment: Affirmed

John D. Lewis, Law Director, City of Conneaut, 294 Main Street, Conneaut, OH 44030 (For Plaintiff-Appellee).

Margaret Brunarski, Ashtabula County Public Defender, Phillip L. Heasley and Michael J. Ledenko, Assistant Public Defenders, 22 East Jefferson Street, Jefferson, OH 44047 (For Defendant-Appellant).

EUGENE A. LUCCI, P.J.

{¶1} Appellant, Christopher Fromknecht, appeals the entry finding him to have

violated the conditions of his community control and ordering execution of a previously

suspended 180-day jail term. We affirm.

{¶2} In March 2022, complaints were filed in the trial court in four separate

“subcases” charging Fromknecht with aggravated menacing, a first-degree

misdemeanor, in violation of the Codified Ordinances of the City of Conneaut (“Loc.Ord.”) 537.05(a); telecommunications harassment, a first-degree misdemeanor, in violation of

R.C. 537.10(A)(3); theft, a first-degree misdemeanor, in violation of Loc.Ord.

545.05(a)(1); and criminal trespass, a fourth-degree misdemeanor, in violation of

Loc.Ord. 541.05(a)(1).

{¶3} Fromknecht initially pleaded not guilty to the charges. Following plea

negotiations, Fromknecht pleaded guilty to the theft and aggravated menacing charges,

and the telecommunications harassment and criminal trespass charges were dismissed.

In 2022, the trial court sentenced Fromknecht to 180 days of confinement on the

aggravated menacing charge, suspending 120 days subject to the conditions of

supervised community control for three years, and to 180 days of confinement on the theft

charge, suspending the entirety of the jail sentence subject to the conditions of supervised

community control for three years. The entries provided that the sentences be served

consecutively to the sentences in all other cases. The aggravated menacing sentencing

entry provided that Fromknecht would have no contact with the victim.

{¶4} In May 2023, a community control revocation complaint was filed against

Fromknecht. Fromknecht admitted violating the terms of community control. As a result,

the court ordered that the balance of the jail term imposed in the aggravated menacing

case be served. The trial court continued the suspension of the 180-day term of

confinement imposed in the theft case, subject to conditions of community control, which

it extended by two years and included the condition that Fromknecht have no contact with

the victim.

{¶5} On July 26, 2023, another revocation complaint was filed alleging that

Fromknecht had not complied with the terms of community control in that he violated the

Case No. 2023-A-0051 no contact order after Fromknecht had been mistakenly released from confinement due

to a stay of execution issued in a separate case. At the final revocation hearing, the victim

testified that Fromknecht sent her a threatening email, which she read aloud. A

screenshot of the email that the victim sent to law enforcement was admitted into

evidence.

{¶6} After hearing, the trial court issued an order finding that Fromknecht violated

the terms of community control in the theft case. The court ordered him to serve 180

actual jail days, with 2 days of credit, consecutively to all other cases.1

{¶7} In his sole assigned error, Fromknecht argues:

The trial court clearly and convincingly committed prejudicial error that deprived Christop[h]er Fromknecht of due process of law as guaranteed by the Fourteenth Amendment to the United States Constitution and Article One, Section Ten of the Ohio Constitution and violated Revised Code 2953.08 by sentencing him to maximum and consecutive sentences.

{¶8} At the outset, we note that Fromknecht maintains that this court should

review misdemeanor sentences under the statutory framework applicable to felony

sentences. However, R.C. 2953.08 and case law relevant to felony sentencing do not

apply to misdemeanor convictions. State v. Fromknecht, 11th Dist. Ashtabula Nos. 2023-

A-0041, 2023-A-0043, 2023-Ohio-4604, ¶ 4. Accordingly, to the extent that Fromknecht

argues that the trial court violated R.C. 2953.08, his assigned error lacks merit.

1. Four identical notices of appeal were filed from this order issued in the Conneaut Municipal Court Case No. 22 CRB 136 C. Each appeal was assigned a separate appellate case number corresponding with the trial court’s Case Nos. 22 CRB 136 A, B, C, and D. However, as only one order issued in Case No. 22 CRB 136 C is the subject of the appeals, this court previously issued a judgment entry dismissing the three duplicative appeals that were assigned to the remaining trial court case numbers as nullities. 3

Case No. 2023-A-0051 {¶9} Next, with respect to misdemeanor sentencing, we note that R.C.

2929.21(A) provides that the sentencing court “shall be guided by the overriding purposes

of misdemeanor sentencing.”

The overriding purposes of misdemeanor sentencing are to protect the public from future crime by the offender and others and to punish the offender. To achieve those purposes, the sentencing court shall consider the impact of the offense upon the victim and the need for changing the offender’s behavior, rehabilitating the offender, and making restitution to the victim of the offense, the public, or the victim and the public. . R.C. 2929.21(A). In addition, R.C. 2929.21(B) provides that such a sentence “shall be

reasonably calculated to achieve the two overriding purposes of misdemeanor sentencing

set forth in division (A) of this section, commensurate with and not demeaning to the

seriousness of the offender’s conduct and its impact upon the victim, and consistent with

sentences imposed for similar offenses committed by similar offenders.” In exercising its

discretion, the court must consider several specific factors contained in R.C.

2929.22(B)(1) and “may consider any other factors that are relevant to achieving the

purposes and principles of sentencing set forth in [R.C. 2929.21].” R.C. 2929.22(B)(2).

{¶10} Further, “‘[a] jail term or sentence of imprisonment for a misdemeanor shall

be served consecutively to any other prison term, jail term, or sentence of imprisonment

when the trial court specifies that it is to be served consecutively * * *, except that the

aggregate term to be served shall not exceed eighteen months.’” Fromknecht, 2023-

Ohio-4604, at ¶ 7, quoting R.C. 2929.41(B)(1). “‘The trial court is not required to make

consecutive sentence findings under R.C. 2929.14(C)(4) prior to ordering consecutive

sentences for jail terms imposed for misdemeanor offenses.’” Fromknecht at ¶ 7, quoting

State v. Henson, 12th Dist. Clermont No. CA2020-07-037, 2021-Ohio-38, ¶ 17. “‘The trial

Case No. 2023-A-0051 court need only “specify” that the jail terms being imposed were to be served

consecutively.’” Fromknecht at ¶ 7, quoting Henson at ¶ 17.

{¶11} Here, Fromknecht maintains that the trial court abused its discretion in

failing to discuss the R.C. 2929.22(B) factors on the record prior to ordering him to serve

the 180-day consecutive sentence. However, as previously noted in our recitation of the

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Bluebook (online)
2024 Ohio 1119, Counsel Stack Legal Research, https://law.counselstack.com/opinion/conneaut-v-fromknecht-ohioctapp-2024.