State v. Allen

2024 Ohio 5386, 257 N.E.3d 510
Procedural entryThis page is a short order in State v. Allen. Read the opinion of the Court — 2022 Ohio 268
Ohio Court of Appeals·Decided November 7, 2024·No. 24CA1187·Published

Opinion

[Cite as State v. Allen, 2024-Ohio-5386.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT ADAMS COUNTY

STATE OF OHIO, : : Case No. 24CA1187 Plaintiff-Appellant, : : v. : DECISION AND JUDGMENT : ENTRY ROBERT ALLEN, : : Defendant-Appellee. : RELEASED: 11/07/2024

APPEARANCES:

Aaron Haslam, Adams County Prosecuting Attorney, and Tyler E. Cantrell, Assistant Adams County Prosecuting Attorney, West Union, Ohio, for appellant.

Robert Allen, Lockbourne, Ohio, pro se, appellee.1

Wilkin, J.

{¶1} The State appeals the Adams County Court’s judgment entry finding

Robert Allen guilty of theft and ordering Allen to pay the victim, Matthew Rigdon,

restitution for the items Allen stole. In its sole assignment of error, the State

asserts that the trial court violated the victim’s constitutional rights under Marsy’s

Law and the prosecution’s rights by failing to notify them of the sentencing

hearing, and by failing to order a restitution amount of the actual loss suffered by

the victim.

{¶2} We are unable to address the merits of the State’s arguments

because we lack jurisdiction. The State did not request leave to appeal and the

1 Allen did not appear or otherwise participate in this appeal. Adams App. No. 24CA1187 2

issue presented is not one that the State may appeal as of right pursuant to R.C.

2945.67(A).

FACTS AND PROCEDURAL BACKGROUND

{¶3} In August 2020, a criminal complaint was filed at the Adams County

Court alleging Allen committed theft, as a first-degree misdemeanor, in which the

value of the items stolen was less than $1,000. The victim of the offense was

Matthew Rigdon. Allen’s arraignment was scheduled for August 17, 2020, but he

failed to appear. A bench warrant was issued on August 19, 2020. The warrant

was recalled on February 9, 2024.

{¶4} The document recalling Allen’s bench warrant was sent to Adams

County Sheriff’s office and requested that Franklin County Sheriff’s office be

notified, where Allen was arrested. Additionally, on this document, there are

other handwritten notes indicating that there is a court hearing on February 12,

2024. Based on the case docket, no other notices were sent out.

{¶5} At the February 12, 2024 arraignment hearing, Allen appeared in

person without counsel. Neither the State nor the victim were present. The trial

court provided Allen with a copy of the complaint and read it to him. Allen

informed the trial court that he wished to plead no contest to the offense. The

trial court explained that once he waives his rights and pleads no contest, the trial

court may find him guilty of theft with no further proceedings, including a jury trial.

Allen responded that he understood. The trial court then explained the rights

Allen would be waiving and questioned Allen to determine whether he was

voluntarily, knowingly, and intelligently pleading no contest. Adams App. No. 24CA1187 3

{¶6} Allen indicated that he understood and signed a waiver of right to

counsel, waiver of right to jury trial, and a waiver of his constitutional and non-

constitutional rights for pleading no contest to theft. After waiving all these rights,

Allen pleaded no contest to the offense of theft as a first-degree misdemeanor.

The trial court accepted Allen’s no contest plea and asked him to elaborate on

the facts of the crime.

{¶7} Allen stated that in June 2020, he had car trouble and needed tools

to fix the car. He took a tool box and a garden hose from the victim, but never

returned them. The trial court accepted the facts as conveyed by Allen and

found that the facts supported the finding of guilt.

{¶8} The trial court proceeded to sentencing informing Allen that the court

did not wish to send him to jail or place him on probation but that he owes

restitution to the victim. The trial court inquired of the value of the items, and

Allen initially estimated $500, and stated that the tool box did not have many

items in it. Allen later advised the trial court that on Amazon the tool box was

$295 and a garden hose is $30. The trial court accepted Allen’s valuation of the

items and ordered restitution of $325 to be paid to the victim. Additionally, the

trial court ordered Allen to pay court costs and a $50 fine. The trial court

released Allen’s $500 bond to be used to pay the court costs, the fine, and

restitution.

{¶9} It is from this judgment entry that the State appeals.

ASSIGNMENT OF ERROR Adams App. No. 24CA1187 4

THE COURT ERRED IN ALLOWING SENTENCING TO BE CONDUCTED WITHOUT THE STATE OF OHIO NOR THE VICTIM TO BE PRESENT OR NOTIFIED.

{¶10} The State maintains that the trial court violated Crim.R. 32, Crim.R.

37, R.C. 2930, and the Ohio Constitution Article I, Section 10a, when it failed to

notify the State nor the victim of the sentencing hearing. According to the State,

the trial court proceeded from arraignment to sentencing without any notification

to the prosecution or the victim. Thus, the victim’s rights were violated where the

victim did not have the opportunity to inform the trial court of the actual economic

loss he suffered from Allen’s theft.

I. Law and analysis

{¶11} In 2017, Article I, Section 10 of the Ohio Constitution was amended

with the voters adopting the initiative known as Marsy’s Law. See State v. Fisk,

2022-Ohio-4435, ¶ 7, citing Ohio Secretary of State, Ballot Board: 2017. The

purpose of the amendment is to “secure for victims justice and due process

throughout the criminal and juvenile justice systems[.] ” Ohio Const., art. I,

§10a(A). The victims’ rights “shall be protected in a manner no less vigorous

than the rights afforded to the accused” and include:

(2) upon request, to reasonable and timely notice of all public proceedings involving the criminal offense or delinquent act against the victim, and to be present at all such proceedings; (3) to be heard in any public proceeding involving release, plea, sentencing, disposition, or parole, or in any public proceeding in which a right of the victim is implicated; ... (7) to full and timely restitution from the person who committed the criminal offense or delinquent act against the victim; ... (10) to be informed, in writing, of all rights enumerated in this section. Adams App. No. 24CA1187 5

Id., §10a(A)(1), (2), (3), (7) and (10).

{¶12} Moreover, the provisions outlining the victims’ rights are “self-

executing and severable, and shall supersede all conflicting state laws.” Id.,

§10a(E).

{¶13} As the plain wording of Marsy’s Law demonstrates, the victim

Matthew Rigdon had the right to be notified of Allen’s sentencing hearing and to

be heard. This includes being heard on the issue of restitution. Pursuant to R.C.

2929.28(A)(1), the trial court was required to order full restitution for any

expenses related to a victim's economic loss due to the criminal offense. R.C.

2929.01(L) defines economic loss as “any economic detriment suffered by a

victim as a direct and proximate result of the commission of an offense and

includes . . . any property loss . . . incurred as a result of the commission of the

offense[.]” And “[n]othing in Marsy’s Law explicitly or implicitly changes what

losses qualify for restitution in Ohio. Consequently, “restitution” continues to

mean compensation for economic losses or economic detriment suffered by the

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State v. Allen, 2024 Ohio 5386, 257 N.E.3d 510 (Ohio Ct. App. 2024).

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