Oregon v. Gaughan

2020 Ohio 4092
CourtOhio Court of Appeals
DecidedAugust 14, 2020
DocketL-19-1084
StatusPublished
Cited by4 cases

This text of 2020 Ohio 4092 (Oregon v. Gaughan) 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
Oregon v. Gaughan, 2020 Ohio 4092 (Ohio Ct. App. 2020).

Opinion

[Cite as Oregon v. Gaughan, 2020-Ohio-4092.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio/City of Oregon Court of Appeals No. L-19-1084

Appellee Trial Court No. 18CRB01253

v.

Robert F. Gaughan DECISION AND JUDGMENT

Appellant Decided: August 14, 2020

*****

Melissa Purpura, City of Oregon Prosecutor, for appellee.

Angelina Wagner, for appellant.

ZMUDA, P.J.

{¶ 1} Appellant, Robert. F. Gaughan, appeals the April 2, 2019 judgment of the

Oregon Municipal Court, sentencing him to 180 days in jail and imposing a $200 fine

following his conviction for domestic violence. For the reasons that follow, we reverse

the trial court’s judgment. I. Background

{¶ 2} On December 5, 2018, appellant was indicted on one count of domestic

violence in violation of R.C. 2929.25(A), a first-degree misdemeanor. The charge arose

from an altercation between appellant and his then-girlfriend, M.K., which occurred the

previous day at a retail store located in Oregon, Ohio. As appellant and the victim argued

over the use of a state-issued benefit card, appellant allegedly threw the card at M.K. and

elbowed her in her tailbone. Appellant was arrested later that day. Following his arrest,

appellant appeared before the Oregon Municipal Court for a hearing on the issuance of a

temporary protection order and to determine his bond. Appellant consented to the

granting of the temporary protection order which was issued the same day. The trial

court ordered appellant to be held in custody pending payment of a $50,000 bond and

conditioned any release on appellant submitting to GPS monitoring. Appellant requested,

and the trial court appointed him defense counsel based on his indigency status.

{¶ 3} Appellant and his appointed counsel appeared before the trial court on

December 7, 2018, and entered a not guilty plea to the single count against him. On

December 11, 2018, appellant again appeared before the trial court for a change of plea

hearing. Appellant informed the trial court that M.K. “has a habit of calling and saying

things that don’t really happen.” Appellant also described the allegation against him as

“false.” Nevertheless, appellant stated that because he was facing termination of his

employment and homelessness while the charge was pending that entering a no contest

plea was “pretty much what [he has] to do” in order to be released. The trial court

2. accepted appellant’s plea and ordered him to participate in a presentencing investigation.

Appellant was released on his own recognizance pending sentencing and ordered to have

no contact with the victim. The trial court set the matter for sentencing on February 5,

2019. At sentencing, appellant informed the trial court that he had learned of a potential

basis to support a motion to withdraw his plea. The trial court continued the sentencing

hearing to February 11, 2019, to permit appellant to discuss this issue with counsel.

{¶ 4} On that date, appellant filed a motion to withdraw his no contest plea

pursuant to Crim.R. 32.1. Appellant’s motion alleged that M.K. provided a victim impact

statement during the presentencing investigation which provided exculpatory information

related to the domestic violence charge—namely, that the incident did not occur.

Appellant argued that the inconsistent statement, of which he was not and could not have

been aware of at the time he entered his plea, could provide him with a complete defense

to the charge. On March 15, 2019, appellant filed a motion for the trial court to release a

copy of M.K.’s victim impact statement to him pursuant to R.C. 2930.14. A combined

hearing on appellant’s motions was conducted on April 2, 2019. The state filed its

opposition to appellant’s motion to withdraw his plea and his motion for release of

M.K.’s victim impact statement on the day of the hearing. The state argued, essentially,

that because appellant’s plea was properly entered under the Rules of Criminal

Procedure, and without knowledge of M.K.’s subsequent recantation of the underlying

event, that he had knowingly entered his plea and his motion should be denied. The

3. state’s opposition did not address whether the impact of M.K.’s statement could support a

defense for appellant.

{¶ 5} At the hearing, the trial court first heard the parties’ arguments on

appellant’s motion for release of the victim impact statement. The trial court orally

denied appellant’s motion and proceeded to conduct a hearing on appellant’s motion to

withdraw his plea.1 Over the state’s objection, appellant called M.K. as the only witness

at the hearing. On appellant’s direct examination, M.K stated that she did not recall

providing a victim impact statement in which she stated that the altercation between her

and appellant did not occur. Appellant attempted to refresh M.K.’s recollection of her

victim impact statement by asking the trial court to release a copy for the purposes of

M.K.’s testimony only. The state objected arguing the trial court’s prior decision not to

release the statement precluded it from being used during M.K.’s testimony. The trial

court sustained the state’s objection. Appellant then sought to have the trial court provide

M.K. with a copy of her statement without releasing it to counsel to refresh her

recollection. The trial court also denied this request and appellant concluded his

questioning of M.K.

{¶ 6} During the state’s cross-examination, M.K. acknowledged that she did

indeed provide a victim impact statement in which she stated that she was not injured

1 Appellant did not appeal the trial court’s denial of his motion for release of the victim impact statement; accordingly, that issue is not before us.

4. during the altercation with appellant. She acknowledged that this version of events was

inconsistent with her original statement to the City of Oregon Police officer where she

claimed appellant had assaulted her which resulted in appellant’s arrest. She further

testified that she provided this inconsistent statement based on her belief that it could

prevent appellant from receiving a sentence which precluded him from seeing their child.

M.K. also recounted a subsequent March 23, 2019 conversation that she had with the

presentencing investigation officer in which she stated that her victim impact statement

regarding the lack of injury was false and made solely for the purpose of helping

appellant receive a lesser sentence.

{¶ 7} On re-direct examination, appellant’s counsel noted that M.K. appeared to

have a better recollection of her statements when questioned by the state than she did

during his direct examination. M.K. offered no response to this commentary but again

acknowledged providing a victim impact statement that was inconsistent with her prior

version of events which led to appellant’s arrest. Despite acknowledging that her victim

impact statement was inconsistent with what she told police, M.K. denied stating that she

had initially lied to the police about her altercation with appellant.

{¶ 8} Following appellant’s questioning, the trial court engaged in its own

examination of M.K. in which the following exchange occurred:

The Court: Ma’am, in the, looking at the Complaint, the Complaint

reads that the suspect elbowed the victim, you, in the tailbone. Did that

happen?

5.

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2020 Ohio 4092, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oregon-v-gaughan-ohioctapp-2020.