Sate v. Smith

2026 Ohio 387
CourtOhio Court of Appeals
DecidedFebruary 6, 2026
Docket24 BE 0058
StatusPublished

This text of 2026 Ohio 387 (Sate v. Smith) 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
Sate v. Smith, 2026 Ohio 387 (Ohio Ct. App. 2026).

Opinion

[Cite as Sate v. Smith, 2026-Ohio-387.]

IN THE COURT OF APPEALS OF OHIO SEVENTH APPELLATE DISTRICT BELMONT COUNTY

STATE OF OHIO,

Plaintiff-Appellant,

v.

KENNETH SMITH,

Defendant-Appellee.

OPINION AND JUDGMENT ENTRY Case No. 24 BE 0058

Application to Reopen

BEFORE: Katelyn Dickey, Carol Ann Robb, Mark A. Hanni, Judges.

JUDGMENT: Denied.

Atty. J. Kevin Flanagan, Belmont County Prosecutor, and Atty. Jacob A. Manning, Assistant Prosecuting Attorney, for Plaintiff-Appellee (No Response Filed) and

Kenneth Smith, Defendant-Appellant.

Dated: February 6, 2026 –2–

PER CURIAM.

{¶1} On December 17, 2025, pro se Appellant, Kenneth Smith, filed an App.R. 26(B) application to reopen his direct appeal in State v. Smith, 2025-Ohio-4578 (7th Dist.). Appellee, the State of Ohio, did not file a response. {¶2} Appellant was convicted of possession of a fentanyl-related compound and aggravated possession of drugs (methamphetamine) and consecutively sentenced to a total aggregate sentence of 15 to 20 and one-half years in prison following a bench trial. In Appellant’s direct appeal, appellate counsel asserted Appellant’s convictions were not supported by the manifest weight of the evidence. Appellate counsel also alleged Appellant’s consecutive sentences were not supported by the record. This court found no merit in either argument and affirmed the trial court’s judgment on September 30, 2025. Smith at ¶ 1, 42.

App.R. 26(B)(1) and (2)(b) require applications to reopen based on ineffective assistance of appellate counsel to be filed within ninety days from journalization of the decision. App.R. 26(B)(1), (2)(b); State v. Gumm, 103 Ohio St.3d 162, 2004-Ohio-4755, 814 N.E.2d 861. The ninety-day requirement applies to all appellants. State v. Buggs, 7th Dist. Mahoning Nos. 06 MA 28, 07 MA 187, 2009-Ohio-6628, ¶ 5.

If an application for reopening is not filed within the ninety day time period, an appellant must make a showing of good cause justifying the delay in filing. State v. Dew, 7th Dist. Mahoning No. 08 MA 62, 2012-Ohio-434.

State v. Frazier, 2020-Ohio-993, ¶ 5-6 (7th Dist.).

{¶3} As stated, Appellant’s pro se application for reopening was filed on December 17, 2025. Therefore, his application is timely as it was filed within the 90-day timeframe of this court’s September 30, 2025 decision. Smith, 2025-Ohio-4578 (7th Dist.); App.R. 26(B)(1) and (2)(b). Upon review, however, Appellant fails to meet the standard for reopening this appeal. See State v. Romeo, 2018-Ohio-2482, ¶ 6 (7th Dist.).

Case No. 24 BE 0058 –3–

Claims of ineffective assistance of appellate counsel under App.R. 26(B) are subject to the two-pronged analysis enunciated in Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984). See State v. Simpson, 164 Ohio St.3d 102, 2020-Ohio-6719, 172 N.E.3d 97, ¶ 14, Id. at ¶ 23 (O’Connor, C.J., concurring), Id. at ¶ 28 (Fischer, J., concurring); State v. Reed, 74 Ohio St.3d 534, 535, 660 N.E.2d 456 (1996); see also 1993 Staff Notes to App.R. 26 (“The term ‘ineffective assistance of counsel’ is intended to comprise the two elements set forth in Strickland”).

In accordance with the Strickland analysis, an applicant must show that (1) appellate counsel’s performance was objectively unreasonable, id. at 687, 104 S.Ct. 2052, and (2) there is “a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different,” id. at 694, 104 S.Ct. 2052. See Smith v. Robbins, 528 U.S. 259, 285-286, 120 S.Ct. 746, 145 L.Ed.2d 756 (2000). . . .

State v. Leyh, 2022-Ohio-292, ¶ 17-18.

Under App.R. 26(B), an applicant must set forth “[o]ne or more assignments of error or arguments in support of assignments of error that previously were not considered on the merits in the case by any appellate court or that were considered on an incomplete record because of appellate counsel’s deficient representation.” App.R. 26(B)(2)(c).

State v. Hackett, 2019-Ohio-3726, ¶ 9 (7th Dist.).

[Furthermore] [i]t should finally be noted that appellate counsel need not raise every possible issue in order to render constitutionally effective assistance. [State v.] Tenace, 109 Ohio St.3d 451 at ¶ 7, 849 N.E.2d 1, citing State v. Sanders (2002), 94 Ohio St.3d 150, 151-152, 761 N.E.2d 18. “Experienced advocates since time beyond memory have emphasized the importance of winnowing out weaker arguments on appeal and focusing on one central issue if possible, or at most on a few key issues.” Jones v. Barnes (1983), 463 U.S. 745, 751, 103 S.Ct. 3308, 77 L.Ed.2d 987.

Case No. 24 BE 0058 –4–

State v. Jones, 2008-Ohio-3352, ¶ 6 (7th Dist.).

{¶4} In support of his position to reopen this appeal, Appellant raises three assignments of error. Appellant’s pro se assignments are voluminous in length but can be briefly summarized as follows: (1) appellate counsel’s decision to not raise any argument challenging the jury waiver is ineffective assistance because Appellant’s oral waiver was invalid since it was not made in a knowing manner in “open court”; (2) appellate counsel’s decision to not raise a sufficiency of the evidence argument is ineffective assistance; and (3) appellate counsel was deficient for failing to raise a malicious prosecution claim because the weight of the evidence to convict him was deficient. See (12/17/2025 Appellant’s Application to Reopen, p. 2-3, 4-5); (12/4/2025 Appellant’s Affidavit, p. 9). {¶5} Regarding Appellant’s first assignment of error, appellate counsel’s decision to not raise any argument challenging the jury waiver does not amount to ineffective assistance. {¶6} Appellant claims his oral waiver was invalid because it was not made in a knowing manner in “open court.”

“[T]he term ‘open court’ means that court is in session and the judge is on the bench.” State v. Davis, 2008-Ohio-6741, ¶ 15 (9th Dist.), quoting State v. Monroe, 2000 WL 807228, *5 (4th Dist. June 14, 2000). “To satisfy the ‘in open court’ requirement in R.C. 2945.05, there must be some evidence in the record that the defendant while in the courtroom and in the presence of counsel, if any, acknowledged the jury waiver to the trial court.” Lomax, 2007-Ohio-4277, at paragraph two of the syllabus.

State v. Mason, 2024-Ohio-2796, ¶ 11 (9th Dist.).

{¶7} The record reflects Appellant was indicted on January 4, 2024. Appellant was appointed counsel and pled not guilty at his arraignment. However, multiple counsel were later appointed and permitted to withdraw. Following delays associated with bringing in new counsel and allowing counsel to withdraw, a jury trial was set for December 17, 2024.

Case No. 24 BE 0058 –5–

{¶8} Appellant had been released on bond, but on October 9, 2024, Appellant’s urine tested positive for cannabinoid and cocaine. Therefore, the State filed a motion to revoke bond. At a hearing held on October 21, 2024, Appellant’s bond was revoked and he was detained pending the jury trial. Appellant’s fourth counsel moved to withdraw due to a breakdown in communication with Appellant but the trial court overruled the motion. {¶9} The parties appeared for the scheduled jury trial on December 17, 2024. As the jury was waiting in the hallway, Appellant was present in the courtroom with his trial counsel.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jones v. Barnes
463 U.S. 745 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Smith v. Robbins
528 U.S. 259 (Supreme Court, 2000)
State v. Dew
2012 Ohio 434 (Ohio Court of Appeals, 2012)
State v. Littlejohn
2012 Ohio 1064 (Ohio Court of Appeals, 2012)
State v. Davis, 08ca009412 (12-22-2008)
2008 Ohio 6741 (Ohio Court of Appeals, 2008)
State v. Jones, 06 Ma 17 (6-26-2008)
2008 Ohio 3352 (Ohio Court of Appeals, 2008)
State v. Frazier
2020 Ohio 993 (Ohio Court of Appeals, 2020)
State v. Simpson (Slip Opinion)
2020 Ohio 6719 (Ohio Supreme Court, 2020)
State v. Leyh (Slip Opinion)
2022 Ohio 292 (Ohio Supreme Court, 2022)
State v. Reed
660 N.E.2d 456 (Ohio Supreme Court, 1996)
State v. Sanders
761 N.E.2d 18 (Ohio Supreme Court, 2002)
State v. Gumm
814 N.E.2d 861 (Ohio Supreme Court, 2004)
State v. Tenace
849 N.E.2d 1 (Ohio Supreme Court, 2006)
State v. Orrell
2024 Ohio 1194 (Ohio Court of Appeals, 2024)
State v. Mason
2024 Ohio 2796 (Ohio Court of Appeals, 2024)
State v. Smith
2025 Ohio 4578 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 387, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sate-v-smith-ohioctapp-2026.