State v. Arnoff

2020 Ohio 3520
CourtOhio Court of Appeals
DecidedJune 30, 2020
Docket19CA011475
StatusPublished
Cited by1 cases

This text of 2020 Ohio 3520 (State v. Arnoff) 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. Arnoff, 2020 Ohio 3520 (Ohio Ct. App. 2020).

Opinion

[Cite as State v. Arnoff, 2020-Ohio-3520.]

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

STATE OF OHIO C.A. No. 19CA011475

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE BRUCE ARNOFF COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellant CASE No. 18CR098905

DECISION AND JOURNAL ENTRY

Dated: June 30, 2020

HENSAL, Judge.

{¶1} Bruce Arnoff appeals from the judgment of the Lorain County Court of Common

Pleas. This Court affirms.

I.

{¶2} This appeal stems from Mr. Arnoff’s involvement in hiring another person to shoot

and kill an acquaintance. A grand jury indicted Mr. Arnoff on three counts of complicity to commit

aggravated murder (all special felonies), six counts of complicity to commit murder (all special

felonies), six counts of complicity to commit felonious assault (all second-degree felonies), and

two counts of tampering with evidence (both third-degree felonies). Each complicity-to-commit-

aggravated-murder, complicity-to-commit-murder, and complicity-to-commit-felonious-assault

count included an accompanying firearm specification.

{¶3} After initially pleading not guilty, Mr. Arnoff pleaded guilty to all 17 counts of the

indictment. The trial court held a combined change-of-plea and sentencing hearing on December 2

10, 2018. During that hearing, the trial court advised Mr. Arnoff that it had sat through Mr.

Arnoff’s co-defendant's trial, and that it was familiar with the facts and evidence against him. After

accepting his guilty plea, the trial court advised Mr. Arnoff that the prison time for the complicity-

to-commit-aggravated-murder and complicity-to-commit-murder counts, as well as the 15 firearm

specifications, was mandatory prison time. Mr. Arnoff confirmed that he understood.

{¶4} Mr. Arnoff’s counsel requested that the trial court refer Mr. Arnoff for a

presentence-investigation report to aid the court in its sentencing, and to allow Mr. Arnoff time to

conclude some business matters prior to his sentencing. In response, the State indicated that it was

ready to proceed with sentencing, that the sentences were mandatory, and that it could provide the

court with Mr. Arnoff’s prior criminal history. The trial court denied Mr. Arnoff’s counsel’s

request for a presentence-investigation report, noting that the sentences were mandatory. The trial

court then proceeded with sentencing, during which the State orally advised the trial court of Mr.

Arnoff’s criminal history, but did not introduce any supportive documentation.

{¶5} Because the complicity-to-commit-aggravated-murder, complicity-to-commit-

murder, and complicity-to-commit-felonious-assault counts were all allied offenses, the State

elected to proceed with sentencing on count two of the indictment, i.e., complicity to commit

aggravated murder under Sections 2923.03(A)(2) and 2903.01(A), along with the accompanying

firearm specification. The trial court sentenced Mr. Arnoff to mandatory life imprisonment with

parole eligibility after 30 years for that count, as well as two years of imprisonment for each of the

two tampering-with-evidence counts. The trial court ordered the tampering-with-evidence

sentences to run concurrently with the 30-year sentence for the complicity-to-commit-aggravated-

murder count. It then sentenced Mr. Arnoff to a mandatory term of three years of imprisonment

for the firearm specification that accompanied the complicity-to-commit-aggravated-murder 3

count. The trial court ordered that three-year sentence to run consecutively to Mr. Arnoff’s 30-

year sentence for a total sentence of mandatory life imprisonment with parole eligibility after 33

years.

{¶6} Mr. Arnoff subsequently filed a pro se motion to withdraw his guilty plea with the

trial court, as well as a motion for a delayed appeal with this Court. This Court ultimately accepted

Mr. Arnoff’s appeal, which raises two assignments of error for this Court’s review.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT COMMITTED REVERSIBLE AND PLAIN ERROR BY IMPOSING A MANDATORY SENTENCE.

{¶7} In his first assignment of error, Mr. Arnoff argues that the trial court erred by

imposing a mandatory sentence. This Court disagrees.

{¶8} Revised Code Section 2953.08(A) provides, in part, that “a defendant who is

convicted of or pleads guilty to a felony may appeal as a matter of right the sentence imposed * *

*.” “The Supreme Court of Ohio has held that ‘an appellate court may vacate or modify a felony

sentence on appeal only if it determines by clear and convincing evidence that the record does not

support the trial court’s findings under relevant statutes or that the sentence is otherwise contrary

to law.’” State v. Daniels, 9th Dist. Wayne No. 17AP0036, 2020-Ohio-1176, ¶ 35, quoting State

v. Marcum, 146 Ohio St.3d 516, 2016-Ohio-1002, ¶ 1; R.C. 2953.08(G)(2). Section

2953.08(D)(3), however, provides that “[a] sentence imposed for aggravated murder or murder

pursuant to sections 2929.02 to 2929.06 of the Revised Code is not subject to review under this

section.” “According to the Ohio Supreme Court, ‘R.C. 2953.08(D) is unambiguous.’” State v.

Ramsay, 9th Dist. Medina No. 19CA0016-M, 2020-Ohio-1203, ¶ 4, quoting State v. Porterfield, 4

106 Ohio St.3d 5, 2005-Ohio-3095, ¶ 17. “The language of Section 2953.08(D)(3) ‘clearly means

what it says: such a sentence cannot be reviewed.’” Id.

{¶9} Mr. Arnoff argues that Section 2929.13(F)(6) allows a trial court to impose a

mandatory sentence for a first or second-degree felony if the defendant was previously convicted

of or pleaded guilty to a first or second-degree felony. He asserts that the State did not introduce

evidence of any prior conviction, and that the prosecutor’s unsworn statement regarding his prior

convictions at the sentencing hearing was not sufficient. He also asserts that, at sentencing,

information was referenced from his co-defendant’s case, which the trial court was not permitted

to rely upon when fashioning its sentence. He, therefore, concludes that this Court must vacate

his sentence and remand the matter for a new sentencing hearing.

{¶10} In response, the State argues that Mr. Arnoff’s reliance upon Section 2929.13(F)(6)

is misplaced because that Section governs sentencing for first and second-degree felonies, and Mr.

Arnoff’s murder convictions were special felonies, not first or second-degree felonies. The State

argues that Mr. Arnoff, therefore, faced a mandatory prison term as a matter of law, and that it was

not required to introduce evidence of his prior convictions. The State also argues that the trial

court did not err by considering information from Mr. Arnoff’s co-defendant’s case at sentencing.

{¶11} As the State points out, Mr. Arnoff was convicted and sentenced for complicity to

commit aggravated murder under Sections 2903.01(A) and 2923.03(A)(2), which is a special

felony. See State v. Williams, 9th Dist. Summit No. 24169, 2009-Ohio-3162, ¶ 2 (noting that

aggravated murder in violation of Section 2903.01(A) is a special felony). Section 2929.02(A)

provides that “[w]hoever is convicted of or pleads guilty to aggravated murder in violation of

section 2903.01 * * * shall suffer death or be imprisoned for life[.]” The prison sentences for

aggravated murder are mandatory and, per Section 2953.08(D)(3), are not subject to appellate 5

review. See State v. Broe, 1st Dist. Hamilton No.

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2023 Ohio 3511 (Ohio Court of Appeals, 2023)

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2020 Ohio 3520, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-arnoff-ohioctapp-2020.