State v. Bankston

2024 Ohio 3017
CourtOhio Court of Appeals
DecidedAugust 8, 2024
Docket113513
StatusPublished
Cited by1 cases

This text of 2024 Ohio 3017 (State v. Bankston) 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. Bankston, 2024 Ohio 3017 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Bankston, 2024-Ohio-3017.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 113513 v. :

ERROL BANKSTON, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: August 8, 2024

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-23-680141-B

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney and Brittany Fletcher, Assistant Prosecuting Attorney, for appellee.

Patrick S. Lavelle, for appellant.

MARY J. BOYLE, J.:

Defendant-appellant, Errol Bankston (“Bankston”), appeals his guilty

plea and sentence from four counts of aggravated robbery. He contends that his plea

was not entered knowingly, intelligently, or voluntarily because he was not properly advised of postrelease control (“PRC”), and that the trial court failed to properly

advise him of PRC at sentencing. For the reasons set forth below, we affirm.

I. Facts and Procedural History

In April 2023, Bankston was charged with six counts of aggravated

robbery, and six counts of robbery, with accompanying one- and three-year

firearm specifications on all counts. The charges arose from a robbery spree that

occurred between March 22nd and April 3rd 2023 at six separate locations in

Cleveland and Euclid, Ohio. During each robbery, Bankston would pretend to

purchase an item with cash and while the register was open, his codefendant,

Xhyair Bennett, would brandish a firearm, point it at the clerk, and demand the

money in the register.1

In November 2023, Bankston pled guilty to four counts of

aggravated robbery, all felonies of the first degree, as well as one, one-year firearm

specification and one, three-year firearm specification. Bankston was sentenced,

in December, to four years in prison on the firearm specifications to be served prior

to and consecutive with the 3 to 4 ½ years on the underlying charges, for a total of

7 to 8 ½ years in prison. His sentence was run concurrent to his sentence in

another criminal case, State v. Bankston, Cuyahoga C.P. No. CR-23-684460-B.

Bankston now appeals, raising two assignments of error for review:

Assignment of Error I: The appellant’s guilty plea was not knowing and voluntarily because the trial court, prior to taking the plea, failed

1 To date, the codefendant has not filed an appeal. to properly advise appellant that he was subject to “bad time” under O.R.C. 2943.032.

Assignment of Error II: The lower court erred when it sentenced appellant without complying with [R.C.] 2929.19(B)(3) which required the court to notify appellant that he is subject to the postrelease control provisions of O.R.C. 2967.28.

II. Law and Analysis

A. Postrelease Control and Guilty Plea

In his first assignment of error, Bankston argues that his guilty plea

was not made knowingly, intelligently, and voluntarily because he was not

sufficiently informed of (1) PRC, (2) the sanctions he faced if he violated PRC, and

(3) “bad time” under R.C. 2943.032. We find no merit to his argument.

The Ohio Supreme Court, in State v. Dangler, 2020-Ohio-2765, ¶ 17,

summarized appellate review of a trial court’s compliance with Crim.R. 11(C) as

follows: “the questions to be answered are simply: (1) has the trial court complied

with the relevant provision of the rule? (2) if the court has not complied fully with

the rule, is the purported failure of a type that excuses a defendant from the burden

of demonstrating prejudice? and (3) if a showing of prejudice is required, has the

defendant met that burden?” If the plea was not made knowingly, intelligently, and

voluntarily, enforcement of that plea is unconstitutional. Id. at ¶ 10.

The Dangler Court further explained that no demonstration of

prejudice is required in two limited circumstances. First, “[w]hen a trial court fails

to explain the constitutional rights that a defendant waives by pleading guilty or no

contest, we presume that the plea was entered involuntarily and unknowingly, and no showing of prejudice is required.” Dangler at ¶ 14. Second, “a trial court’s

complete failure to comply with a portion of Crim.R. 11(C) eliminates the

defendant’s burden to show prejudice.” Id. at ¶ 15.

Here, Bankston complains the record is devoid of any references to

the provisions of R.C. 2943.032, or the sanctions he faced if he violated PRC.

R.C. 2943.032 states:

Prior to accepting a guilty plea * * * the court shall inform the defendant personally that, if the defendant pleads guilty * * *to the felony * * * if the court imposes a prison term upon the defendant for the felony, and if the offender violates the conditions of a post-release control sanction imposed by the parole board upon the completion of the stated prison term, the parole board may impose upon the offender a residential sanction that includes a new prison term of up to nine months, subject to a maximum cumulative prison term for all violations that does not exceed one-half of the definite prison term that is the stated prison term originally imposed upon the offender or, with respect to a non-life felony indefinite prison term, one-half of the minimum prison term included as part of the stated non-life felony indefinite prison term originally imposed on the offender.

PRC is one of the required advisements pursuant to Crim.R. 11,

because it constitutes a portion of the maximum penalty involved in an offense for

which a prison term will be imposed. State v. Shields, 2023-Ohio-1971, ¶ 4-11 (8th

Dist.), citing State v. Fleming, 2006-Ohio-6773, ¶ 7 (8th Dist.). Without an

adequate explanation of PRC from the trial court, a defendant cannot fully

understand the consequences of his plea as required by Crim.R. 11(C). Id.

At the plea hearing in this case, while discussing the maximum

penalty Bankston faced by pleading guilty, the following colloquy between the court

and Bankston ensued: THE COURT: Upon your release from prison, . . . you will be placed on post release control for a mandatory minimum of two years, and up to a maximum of five years. Post release control, PRC, is commonly called parole, but we call it post release control in the State system. When you’re placed on post release control if you violate the Adult Parole Authority may send you back to prison for up to half the original sentence imposed. If you’re convicted of a new felony while on post release control in addition to being punished for the new offense the judge may add an additional consecutive prison term of one year or whatever time remains on your post release control term, whichever is greater.

While on post release control if you fail to report to your parole officer you may be charged with another felony, which is called escape.

Do you have any questions about your rights, the charges, the penalties, or anything that we’ve gone over here today[?] . . .

THE COURT: Mr. Bankston?

DEFENDANT BANKSTON: No, Your Honor.

(Tr. 26-27.)

Bankston acknowledges that during the plea colloquy the trial court

referenced PRC; however, he argues that the court failed to advise him that he faced

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2024 Ohio 3017, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bankston-ohioctapp-2024.