State ex rel. Chavis v. Bur. of Sentence Computation

Ohio Court of Appeals·Decided September 8, 2026·No. 25AP-161·Published

Opinion

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Jeremy Chavis, :

Relator, :

No. 25AP-161

v. :

(REGULAR CALENDAR)

Bureau [of] Sentence Computation, :

Respondent. :

D E C I S I O N

Rendered on September 8, 2026

On brief: Jeremy Chavis, pro se.

On brief: [D. Andrew Wilson], Attorney General, and Salvatore Messina, for respondent.

IN MANDAMUS

ON OBJECTION TO THE MAGISTRATE’S DECISION

LELAND, J.

{¶ 1} Relator, Jeremy Chavis, an inmate, commenced this original action in mandamus seeking an order compelling respondent, Bureau of Sentence Computation (“bureau”), to correct its records to reflect a criminal sentence imposed by the Franklin County Court of Common Pleas following relator’s 2001 criminal conviction.

{¶ 2} In 2001, relator was convicted of two counts of aggravated murder, in violation of R.C. 2903.01, for offenses committed on or about June 26, 1996. The trial court’s sentencing entry imposed a term of “30 years to life” on each aggravated murder count and a single additional 3-year term for merged firearm specifications. (Relator’s Ex. C at 1, attached to Feb. 4, 2025 Compl. for Writ of Mandamus.) The court ordered the

No. 25AP-161 2

terms for the aggravated murder sentences to be served consecutively to each other and consecutively to the firearm specification term.

{¶ 3} On February 4, 2025, relator filed the instant mandamus action. Relator’s complaint alleged that the bureau informed him via written correspondence in 2023 “that his sentence is designated as a ‘Full Sentence’ not eligible for ‘Good Time.’ ” (Compl. at 3.) Relator contends this designation is inconsistent with the trial court’s sentencing entry, and he seeks a writ to compel the bureau to correct its records to remove the “full sentence” designation.

{¶ 4} Pursuant to Civ.R. 53 and Loc.R. 13(M) of the Tenth District Court of Appeals, this matter was referred to a magistrate who issued a decision, including findings of fact and conclusions of law, which is appended hereto. The magistrate recommends denial of the request for a writ on the ground that relator “has not established a clear legal right to the requested relief because the only term of imprisonment for 30 years authorized under former R.C. 2929.03(C)(2) was for full years.” (Appended Mag.’s Decision at ¶ 36.)

{¶ 5} Relator has filed a pro se objection to the magistrate’s decision, asserting the magistrate erred in concluding he failed to demonstrate a clear legal right to have the bureau adjust its records “to reflect a sentence of 30 years to [l]ife imprisonment without the ‘full’ sentence designation.” (Apr. 23, 2026 Relator’s Obj. at 1.) Relator argues, as he did before the magistrate, that the trial court’s sentencing entry did not designate his sentence as a “full” sentence as claimed by the bureau, and he maintains the bureau “is attempting to correct the sentencing court’s error and impose the sentence it believed the court should have imposed.” (Relator’s Obj. at 16.)

{¶ 6} In response, the bureau contends the objection lacks merit because the magistrate correctly found that relator’s aggravated murder sentence is governed by former R.C. 2929.03(C)(2). Specifically, the bureau argues, the magistrate correctly determined the trial court’s imposition of “[30] years to life” necessarily entails “ ‘full years’ as the statute did not allow for any other option when an offender is sentenced [to] this term of confinement.” (Apr. 29, 2026 Respondent’s Response to Obj. at 4.)

{¶ 7} In order to obtain mandamus relief, relator must establish “a clear legal right to the requested relief,” a “clear legal duty” on the part of the bureau to provide it, “and the

No. 25AP-161 3

lack of an adequate remedy in the ordinary course of the law.” State ex rel. Roberts v. Marsh, 2019-Ohio-1569, ¶ 8, citing State ex rel. Waters v. Spaeth, 2012-Ohio-69, ¶ 6.

{¶ 8} As set forth above, relator was convicted in 2001 for two counts of aggravated murder, in violation of R.C. 2903.01, arising out of conduct occurring on or about June 26, 1996. Each count carried multiple specifications, including aggravating circumstance specifications under R.C. 2929.04 and firearm specifications under R.C. 2941.145. As found by the magistrate, because the aggravated murder offenses were committed before July 1, 1996, “the amended sentencing provisions enacted through S.B. 2 did not apply to [relator’s] convictions, even though he was sentenced after the effective date of S.B. 2.” (Appended Mag.’s Decision at ¶ 29, citing State v. Rush, 1998-Ohio-423, paragraph two of the syllabus.)

{¶ 9} The magistrate further observed that, under the version of R.C. 2929.03(C)(2) then in effect, once the jury found an offender guilty of aggravated murder with an aggravating circumstance specification, the statute “ ‘called for one of three sentences.’ ” (Appended Mag.’s Decision at ¶ 30, quoting State ex rel. Davis v. Janas, 2020- Ohio-1462, ¶ 7, fn. 2.) Specifically, the available sentencing options were “ ‘death, life imprisonment with parole eligibility after serving twenty full years of imprisonment, or life imprisonment with parole eligibility after serving thirty full years of imprisonment.’ ” (Emphasis in original and emphasis omitted.) (Appended Mag.’s Decision at ¶ 30, quoting former R.C. 2929.03(C)(2).) Analyzing the text of former R.C. 2929.03(C)(2), the magistrate concluded “the only term of imprisonment for 30 years authorized under former R.C. 2929.03(C)(2) was for full years.” (Appended Mag.’s Decision at ¶ 36.)

{¶ 10} In reaching that determination, the magistrate relied in part on State v.

Rembert, 2014-Ohio-300 (8th Dist.), in which the Eighth District Court of Appeals noted that, “pursuant to the aggravated murder sentencing statute, when a defendant is sentenced to life imprisonment with parole eligibility after either 25 or 30 years, the years are necessarily ‘full’ years, because ‘full’ years are the only available punishment authorized by the statute when a defendant is ordered to serve 25 or 30 years before becoming eligible for parole.” (Emphasis in original.) Rembert at ¶ 15.

{¶ 11} The magistrate also noted the sentencing entry reflects relator was found guilty of both counts “with Specification,” and that the trial transcript “reflects a statement

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by the common pleas court that [relator] ‘was found guilty of two counts of aggravated murder . . . and he was also found guilty of the specifications to those counts and also found guilty of the firearm specifications on each of those counts.’ ” (Appended Mag.’s Decision at ¶ 36, quoting July 9, 2025 Relator’s Submission of Evid. at 2.) The magistrate concluded that, because the trial court sentenced relator to a term of imprisonment for 30 years for the offense of aggravated murder under the former sentencing statute, and “a term of 30 years for such offense was necessarily 30 full years,” relator failed to demonstrate a clear legal right to have the bureau “adjust his records to reflect a sentence of 30 years imprisonment without the ‘full’ sentence designation, or a clear legal duty on the part of the bureau to provide such relief.” (Appended Mag.’s Decision at ¶ 37.)

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