State v. Arnold

2025 Ohio 2547
CourtOhio Court of Appeals
DecidedJuly 18, 2025
DocketWD-24-059
StatusPublished
Cited by3 cases

This text of 2025 Ohio 2547 (State v. Arnold) 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. Arnold, 2025 Ohio 2547 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Arnold, 2025-Ohio-2547.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT WOOD COUNTY

State of Ohio Court of Appeals No. {87}WD-24-059

Appellee Trial Court No. 2023CR0468

v.

Jeffrey Arnold DECISION AND JUDGMENT

Appellant Decided: July 18, 2025

***** Paul A. Dobson, Esq., Prosecutor and David T. Harold, Esq., Assistant Prosecutor, for appellee.

Gene P. Murray, for appellant. *****

ZMUDA, J.

I. Introduction

{¶ 1} This matter is before the court on appeal from the judgment of the Wood

County Common Pleas Court, sentencing appellant, Jeffrey Arnold, to an aggregate

prison term of 60 months following his guilty plea. Finding no error, we affirm. II. Facts and Procedural Background

{¶ 2} In July 2023, the state charged appellant in case No. 2023CR335 with

violating a protection order in violation of R.C. 2919.27(A)(1) and (B)(3)(c), a felony of

the fifth degree. The state alleged that appellant recklessly violated the terms of a

protection order on June 19, 2023, after previously being convicted of violating a

protection order in a prior case. While in custody on that case, appellant’s actions against

employees of the Wood County Justice Center, between August 5 and September 11,

2023, led to a 32-count indictment in the present case, alleging offenses that included 22

counts of aggravated menacing, misdemeanors of the first degree; four counts of

obstructing official business, felonies of the fifth degree; three counts of intimidation,

felonies of the third degree; two counts of assault, felonies of the fifth degree; and one

count of harassment with a bodily substance, a felony of the fifth degree. The assault and

harassment offenses constituted felonies based on the location of the offenses and status

of the victims, the offenses having occurred in a correctional facility against facility

employees.

{¶ 3} Appellant was arraigned on the charges, entered a not guilty plea, and on

September 27, 2023, the trial court referred appellant to the Northwest Ohio Psychiatric

Hospital for a competency evaluation, pursuant to R.C. 2945.371.1 On December 11,

1 Appellant takes issue with the fact that his trial counsel entered pleas of Not Guilty on his behalf to all 32 charges in the indictment and the trial court, “ironically enough…on its own volition entered pleas of Not Guilty for the defendant who was found incompetent and was about to be transported to the Northwest Ohio Psychiatric Hospital

2. 2023, the trial court held a competency hearing and, based on the stipulated competency

evaluation report submitted to the court, determined appellant was not competent to stand

trial at present, with a substantial probability that appellant could be restored to

competency with treatment. The trial court ordered appellant to undergo treatment and

continued the matter for treatment. On January 25, 2024, the trial court entered an order

authorizing medication and treatment, after appellant refused medications and treatment.

{¶ 4} On March 19, 2024, the trial court entered an order on competency, based on

the stipulated report indicating appellant had been restored to competency, and

reactivated proceedings in the case. On May 14, 2024, the trial court scheduled the matter

for a change of plea hearing at appellant’s request.

{¶ 5} On May 21, 2024, appellant appeared for a plea hearing that was combined

with a hearing to address modification to his bond. Appellant entered a guilty plea as to

three counts in the 32-count indictment, as follows: (1) Count 14: assault in violation of

R.C. 2903.13(A) and (C)(4)(a), a felony of the fifth degree; (2) Count 27: intimidation in

violation of R.C. 2921.03(A) and (B), a felony of the third degree; and (3) Count 31:

harassment with a bodily substance in violation of R.C. 2921.38(A) and (D), a felony of

by Court order.” While appellant suggests error in this procedure, he has assigned and pursued no error in this appeal regarding his initial plea of Not Guilty. Furthermore, Crim.R. 11(A) requires the trial court to “enter a plea of not guilty on behalf of the defendant” even if the plea is against the defendant’s wishes. State v. Khamsi, 2020-Ohio- 1472, ¶ 36 (1st Dist.). Finally, appellant subsequently entered a guilty plea, with no attempt to withdraw that plea, and has waived all non-jurisdictional defects occurring prior to the guilty plea. (Citations omitted) State v. Hesser, 2025-Ohio-775, ¶ 6 (6th Dist.).

3. the fifth degree. Pursuant to the negotiated plea, the state agreed to dismiss the indictment

in case No. 2023CR335, as well as the remaining 29 counts in the present case.

{¶ 6} As part of the plea colloquy, appellant acknowledged the maximum penalty

that could include a prison term, including a consecutive sentence. Appellant also

acknowledged that he could receive a community control sanction, but the trial court was

not promising a community control sanction. The trial court specifically addressed the

bond modification to be addressed that would permit appellant’s release on bond, and

clarified that the plea hearing was unrelated to release on bond, as follows:

The Court: Now, I want to make sure something is understood, Mr. Arnold. I think sometimes we do these pleas and it sometimes seems that things are connected. The conditions of bond and the release on bond is a separate consideration. I don’t want you to be entering this plea saying, hey, if I plead, I’m going to get out. That is not connected to this. Do you understand that? [Appellant]: Yes, Your Honor.

The trial court conducted the Crim.R. 11 colloquy, addressing the constitutional rights

appellant waived by entering his guilty plea, and appellant expressed understanding of

the effect of his plea and his desire to proceed.

{¶ 7} The trial court accepted appellant’s plea and found appellant guilty.

{¶ 8} Next, the trial court addressed bond, vacated the prior bond and ordered

appellant released on his own recognizance with conditions, including mental health

treatment, no contact with the victims, a GPS monitor, and a curfew. The trial court

scheduled sentencing for July 23, 2024.

4. {¶ 9} Two months later, appellant appeared for his sentencing hearing. Appellant’s

trial counsel argued in favor of a community control sanction, noting appellant’s efforts

to address his mental health issues and his willingness to cooperate with treatment, as

demonstrated by appellant’s compliance with all conditions of his release, pending

sentencing. The state argued in favor of a prison sentence, highlighting appellant’s long

history of violence that often coincided with the manic periods of appellant’s bipolar

disorder. The state also noted that, despite his mental health history, appellant has never

entered a not guilty by reason of insanity plea, but instead, has always argued his mental

health issues as a mitigating factor, received probation, and then neglected his mental

health.

{¶ 10} Appellant spoke on his own behalf. He indicated that 2023 was a rough

year, “probably the worst year of my life.” He argued, however, that he has had trouble

finding the right medication and a “psychologist that really knows what he’s doing.” He

also argued that his past offenses, like a domestic violence charge, resulted from the

victim attacking appellant, and appellant blamed other incidents on others and “people

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2547, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-arnold-ohioctapp-2025.