State v. Battle

2025 Ohio 4731
CourtOhio Court of Appeals
DecidedOctober 14, 2025
DocketOT-24-047
StatusPublished

This text of 2025 Ohio 4731 (State v. Battle) 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. Battle, 2025 Ohio 4731 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Battle, 2025-Ohio-4731.]

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

State of Ohio Court of Appeals No. OT-24-047

Appellee Trial Court No. CRB-24-00662A

v.

Noah J. Battle DECISION AND JUDGMENT

Appellant Decided: October 14, 2025

***** Mark S. O’Brien, Esq., for appellant.

James E. VanEerten, Esq., Ottawa County Prosecutor and Daivia S. Kasper, Esq., Chief Assistant Prosecutor, for appellee.

*****

ZMUDA, J.

I. Introduction

{¶ 1} Appellant, Noah Battle, appeals from the November 15, 2024 judgment of

the Ottawa County Municipal Court sentencing him to an aggregate jail term of 540 days following his guilty plea to three misdemeanor drug possession offenses. For the

following reasons, we affirm the trial court’s judgment.

A. Facts and Procedural Background

{¶ 2} Appellant was charged via complaint with one count of attempted

aggravated possession of drugs in violation of R.C. 2923.02(A) and 2925.11(A)(C)(1)(a)

and two counts of possession of drugs in violation of R.C. 2925.11(A)(C)(2)(a); each a

first-degree misdemeanor. The charges arose from a traffic stop that occurred on July 31,

2023. When approaching the vehicle, the officer initiating the stop observed the odor of

burnt marijuana. During a subsequent search of appellant’s vehicle, the officer found

appellant in possession of Dextroamphetimine, Tramadol, and Alprazolam.

{¶ 3} Appellant was originally indicted in the Ottawa County Court of Common

Pleas on one count of aggravated possession of drugs, a fifth-degree felony, and two first-

degree misdemeanor possession of drug offenses. Following plea negotiations, the state

agreed to dismiss the common pleas indictment and refile three misdemeanor possession

offenses in the Ottawa County Municipal Court in exchange for appellant’s guilty plea to

the misdemeanor offenses. Appellant entered his guilty plea on September 3, 2024. The

trial court accepted his plea and ordered him to participate in a presentencing

investigation. The court indicated that its primary purpose in ordering the investigation

was to determine “whatever is happening with your life and with substances especially”

so that it could impose “an appropriate punishment[.]” The trial court released appellant

2. pending sentencing on the condition, relevant to the present appeal, that he not ingest any

“substance[s] of abuse.”

{¶ 4} Appellant appeared for sentencing on November 15, 2024. At that time, the

trial court noted that appellant appeared for his initial presentencing interview with the

adult probation department late and that he “reek[ed]” of marijuana at the time. Further,

the court noted that prior to sentencing, appellant did not take part in any of the drug

counseling services available to him. Finally, the court referenced appellant’s appearance

at sentencing, during which he “smell[ed]” of marijuana. Appellant had also tested

positive for marijuana and Suboxone, a substance for which he had not provided a

prescription to the court, during a drug screening administered prior to sentencing. The

trial court also indicated that appellant’s failure to obtain marijuana through a legal

dispensary rendered his use of it illegal. The trial court also noted that appellant had been

offered, and declined, multiple opportunities to seek help with addiction issues while the

charges were pending.

{¶ 5} Appellant argued that his current use of marijuana was legal following the

passage of an amendment to the Ohio Constitution legalizing recreational marijuana and

that he used it to treat his post-traumatic stress disorder. He also denied the use of any

other drugs, including Suboxone, claiming that he had to pass drug tests to maintain his

current employment. He also attributed the smell of marijuana he exhibited at sentencing

to residual odor on his coat from being in the vehicle where he had used marijuana in the

past.

3. {¶ 6} At the conclusion of the hearing, the trial court imposed a 180-day jail term

on each of appellant’s offenses. He ordered appellant to serve those sentences

consecutively for an aggregate jail term of 540 days.

B. Assignment of Error

{¶ 7} Appellant timely appealed the trial court’s judgment and asserts the

following error for our review:

The trial court committed reversible error by imposing upon appellant the maximum sentence permitted by R.C. 2929.24 and 2929.28 based not upon consideration of the principles, purposes and factors required by R.C. 2929.21 and 2929.22, but rather upon its concern for appellant’s ostensible, ongoing use of marijuana – a substance that is legal in the State of Ohio for recreational use.

II. Law and Analysis

{¶ 8} In his single assignment of error, appellant argues that the trial court erred in

imposing his sentence because it did not base the length of that sentence on the principles

and purposes of misdemeanor sentencing, as established in R.C. 2929.21 and 2929.22.

Instead, he argues, the trial court based his sentence “primarily, if not exclusively” on his

marijuana use. Appellant also argues that the record is devoid of the trial court’s

consideration of the statutory factors, rendering his sentence arbitrary.

{¶ 9} We review misdemeanor sentences for an abuse of discretion. State v. Haas,

2025-Ohio-683, ¶ 67 (6th Dist.), citing State v. Johnson, 2019-Ohio-4613, ¶ 31 (6th

Dist.). An abuse of discretion occurs when the trial court’s attitude is unreasonable,

arbitrary, or unconscionable. Blakemore v. Blakemore, 5 Ohio St.3d 217 (1993). Having

4. reviewed the record, we find that the trial court did not abuse its discretion when it

imposed appellant’s sentence.

{¶ 10} Appellant’s argument is premised on two unfounded assertions. First, he

argues that the trial court did not consider the required factors described in R.C. 2929.21

and 2929.22 because it did not expressly state that it had done so. Second, he argues that

the trial court’s mischaracterization of his marijuana use as “illegal” was an improper

factor to consider in determining his sentence. We address these issues in turn.

{¶ 11} As to the trial court’s consideration of the purposes and principles of

misdemeanor sentencing, it is undisputed that the trial court did not expressly reference

its consideration of those factors when it imposed sentence. Appellant argues that the

trial court’s silence as to its consideration of those factors indicates that it did not

consider them. This is incorrect. Instead, when the record is silent as to the trial court’s

consideration of the applicable misdemeanor sentencing factors, we may presume that

they were considered. Haas at ¶ 68. “That presumption will only be destroyed if, for

instance, the trial court introduced an improper factor into the maximum sentencing

determination.” Id. As described below, there is no indication in the record that the trial

court considered an improper factor when it determined appellant’s sentence. As a result,

we presume that the trial court considered the sentencing factors described in R.C.

2929.21 and 2929.22.

{¶ 12} As to the trial court’s alleged focus on appellant’s marijuana use, we find

that the record does not support appellant’s assertion that the court’s primary factor in

5.

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Related

State v. Johnson
2019 Ohio 4613 (Ohio Court of Appeals, 2019)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
State v. Haas
2025 Ohio 683 (Ohio Court of Appeals, 2025)

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Bluebook (online)
2025 Ohio 4731, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-battle-ohioctapp-2025.