State v. Anderson

2025 Ohio 629
CourtOhio Court of Appeals
DecidedFebruary 26, 2025
Docket31182
StatusPublished
Cited by1 cases

This text of 2025 Ohio 629 (State v. Anderson) 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
State v. Anderson, 2025 Ohio 629 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Anderson, 2025-Ohio-629.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

STATE OF OHIO C.A. No. 31182

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE EMERSON M. ANDERSON COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellant CASE No. CR 05 08 3053

DECISION AND JOURNAL ENTRY

Dated: February 26, 2025

SUTTON, Judge.

{¶1} Defendant-Appellant Emerson Anderson appeals the judgment of the Summit

County Court of Common Pleas. For the reasons that follow, this Court reverses and remands for

the trial court to determine if Mr. Anderson satisfied the jurisdictional requirements in R.C.

2953.23(A)(1)(a) and (b), or if the untimely and successive petition for postconviction relief should

be dismissed for lack of jurisdiction.

I.

Relevant Background Information

{¶2} In 2006, a jury returned guilty verdicts against Mr. Anderson on four counts of rape,

three counts of gross sexual imposition, and one count of menacing by stalking. At sentencing, the

trial court merged the three counts of gross sexual imposition into the four counts of rape. Mr.

Anderson was sentenced to mandatory life prison terms on all four counts of rape and a one-year

prison term for the menacing by stalking conviction. Mr. Anderson was also classified as a child- 2

victim predator. Mr. Anderson’s total prison sentence was three life terms with eligibility for

parole after 30 years.

{¶3} Mr. Anderson appealed his convictions raising two assignments of error for this

Court’s review. See State v. Anderson, 2007-Ohio-147 (9th Dist.) (“Anderson I”). In determining

Mr. Anderson’s convictions were supported by sufficient evidence and not against the manifest

weight of the evidence, this Court affirmed the jury verdict. Anderson at ¶ 34. Mr. Anderson then

filed a petition for postconviction relief, arguing ineffective assistance of counsel regarding the

filing of a speedy trial waiver, which was denied by the trial court. Mr. Anderson filed a notice of

appeal to this Court in Case No. 23604, and his appeal was dismissed for failure to file a brief.

{¶4} On March 20, 2024, Mr. Anderson filed his most recent petition for postconviction

relief, pursuant to R.C. 2953.21, seeking an evidentiary hearing. In his petition for postconviction

relief, Mr. Anderson argued he was entitled to relief based upon a claim of ineffective assistance

of trial counsel because he was unaware a speedy trial waiver was filed in this case, and he was

unavoidably prevented from discovery of the facts supporting his petition. Specifically, Mr.

Anderson admitted to filing his petition “well after the [] time limit prescribed in [R.C. 2953.21][,]”

but indicated he could not have discovered the evidence sooner by exercising reasonable due

diligence because: (1) the evidence is not in the record; (2) his trial and appellate attorneys did not

keep him informed of the status of his case “or advise him of anything he could do to help himself

legally[;]” (3) court records/documents were falsified, destroyed, and/or denied to him upon

request; and (4) he cannot afford an attorney or investigator, has limited access to records, and is

ignorant of the law and legal procedure.

{¶5} The State opposed the petition for postconviction relief arguing it is untimely and

should be dismissed because Mr. Anderson did not satisfy the jurisdictional requirements in R.C. 3

2953.23(A)(1)(a) and (b). Specifically, the State noted the speedy trial waiver was apparent from

the record at the time of Mr. Anderson’s direct appeal as it was filed and journalized on October

6, 2005. For this reason, the State argued Mr. Anderson did not prove he was unavoidably

prevented from discovering the facts relied upon in his untimely petition for postconviction relief.

The State, therefore, contended the trial court is without jurisdiction to consider Mr. Anderson’s

untimely petition for postconviction relief and it must be dismissed. The State also suggested that,

even if the trial court had jurisdiction to consider Mr. Anderson’s untimely petition for

postconviction relief, Mr. Anderson’s claims are barred by the doctrine of res judicata because

they could have been raised in his direct appeal.

{¶6} In dismissing Mr. Anderson’s petition for postconviction relief without a hearing,

the trial court did not address whether Mr. Anderson satisfied the jurisdictional requirements in

R.C. 2953.23(A)(1)(a) and (b). Instead, the trial court stated: “[b]efore addressing [Mr.

Anderson’s] arguments related to [R.C. 2953.21], this [c]ourt must first address the issue of res

judicata.” (Italics in original.) The trial court then denied Mr. Anderson’s petition for

postconviction relief, and granted the State’s motion to dismiss, on the basis of res judicata alone.

{¶7} Mr. Anderson appeals, raising one assignment of error for our review.

II.

ASSIGNMENT OF ERROR

THE TRIAL COURT ERRED TO THE PREJUDICE OF [MR. ANDERSON] AND ABUSED ITS DISCRETION BY DENYING [MR. ANDERSON] RELIEF AND DISMISSING [MR. ANDERSON’S] R.C. 2953.21(A) PETITION WITHOUT AN EVIDENTIARY HEARING.

{¶8} In his sole assignment of error, Mr. Anderson argues the trial court erred in

dismissing his petition for postconviction relief without a hearing. 4

{¶9} R.C. 2953.21(A)(2) provides that a petition for postconviction relief must be filed

within 365 days of the date on which the transcript is filed in a direct appeal or, if no direct appeal

is taken, within 365 days of the expiration of the time for filing an appeal. Mr. Anderson’s most

recent petition for postconviction relief was filed approximately 17 years after the transcript was

filed in his direct appeal. Thus, Mr. Anderson’s petition for postconviction relief is untimely.

Further, because Mr. Anderson has filed more than one petition for postconviction relief, his

petition is also successive.

{¶10} “A petitioner . . . who files a petition more than 365 days after the trial transcript

was filed in the court of appeals in his direct appeal . . . must satisfy the jurisdictional requirements

in R.C. 2953.23(A)(1) or (2) for an untimely, second, or successive petition for postconviction

relief.” State v. Hatton, 2022-Ohio-3991, ¶ 37, citing State v. Bethel, 2022-Ohio-783, ¶ 20. See

also State v. Apanovitch, 2018-Ohio-4744, ¶ 22. Pursuant to R.C. 2953.23(A)(1), a trial court may

only entertain an untimely or successive petition for postconviction relief when both of the

following apply:

(a) Either the petitioner shows that the petitioner was unavoidably prevented from discovery of the facts upon which the petitioner must rely to present the claim for relief, or, subsequent to the period prescribed in division (A)(2) of section 2953.21 of the Revised Code or to the filing of an earlier petition, the United States Supreme Court recognized a new federal or state right that applies retroactively to persons in the petitioner's situation, and the petition asserts a claim based on that right.

(b) The petitioner shows by clear and convincing evidence that, but for constitutional error at trial, no reasonable factfinder would have found the petitioner guilty of the offense of which the petitioner was convicted[.]

When the requirements of R.C. 2953.23(A)(1) have not been met, a trial court cannot consider an

untimely or successive petition. See Apanovitch at ¶ 36. Indeed, “a petitioner’s failure to satisfy

R.C.

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Related

State v. Anderson
2025 Ohio 5399 (Ohio Court of Appeals, 2025)

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Bluebook (online)
2025 Ohio 629, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-anderson-ohioctapp-2025.