State v. Bennett

2024 Ohio 274, 234 N.E.3d 629
CourtOhio Court of Appeals
DecidedJanuary 26, 2024
Docket29669
StatusPublished

This text of 2024 Ohio 274 (State v. Bennett) 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. Bennett, 2024 Ohio 274, 234 N.E.3d 629 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Bennett, 2024-Ohio-274.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

STATE OF OHIO : : Appellee : C.A. No. 29669 : v. : Trial Court Case No. 22CRB3640 : DONAVON BENNETT : (Criminal Appeal from Municipal Court) : Appellant : :

...........

OPINION

Rendered on January 26, 2024

APRIL F. CAMPBELL, Attorney for Appellant

MARC T. ROSS, Attorney for Appellee

.............

TUCKER, J.

{¶ 1} Defendant-appellant Donavon Bennett appeals from his conviction for cruelty

to animals. For the reasons set forth below, we reverse and remand for further

proceedings.

I. Facts and Procedural Background -2-

{¶ 2} On October 19, 2022, Bennett was charged by criminal complaint with three

counts of cruelty to animals in violation of R.C. 959.131(B). He was arraigned the next

day, at which time a trial date was set for November 1, 2022. A notice of appearance

was filed by the public defender’s office on October 21, 2022. Bennett filed a written jury

demand and a separate motion for a continuance of the trial on October 31, 2022; the

trial court conducted a hearing on the motions that same day. According to the record,

Bennett was not transported from jail to the hearing due to the late hour of the proceeding.

Ultimately, the trial court rescheduled the trial for November 3, 2022, but denied the jury

demand as untimely.

{¶ 3} Following a bench trial, the court found Bennett guilty of one charge of cruelty

to animals and not guilty of the two other charges. Bennett was sentenced to 180 days

in jail with credit for 14 days. The remaining 166 days were suspended, and Bennett

was placed on intensive supervised probation for one year. The court ordered Bennett

to pay $309 in veterinary bills as restitution. Finally, the court ordered Bennett to attend

a Stop the Violence program and to undergo a psychiatric assessment and assessments

for drug and alcohol abuse.

{¶ 4} Bennett appeals.

II. Entitlement to a Jury Trial

{¶ 5} The first assignment of error asserted by Bennett states:

BENNETT’S CONVICTION SHOULD BE REVERSED BECAUSE

HE WAS ENTITLED TO A JURY TRIAL AND DID NOT WAIVE HIS RIGHT -3-

TO IT.

{¶ 6} “[T]he guarantee of a jury trial in criminal cases contained in the state and

federal Constitutions is not an absolute and unrestricted right in Ohio with respect to

misdemeanors, and a statute, ordinance or authorized rule of court may validly condition

the right to a jury trial in such a case on a written demand therefore.” State v. Tate, 59

Ohio St.2d 50, 52, 391 N.E.2d 738 (1979), quoting Mentor v. Giordano, 9 Ohio St.2d 140,

224 N.E.2d 343 (1967), paragraph one of the syllabus. “Crim.R. 23(A) is such a rule.”

Id. The rule states, in pertinent part:

In petty offense cases, where there is a right of jury trial, the defendant shall

be tried by the court unless he demands a jury trial. Such demand must be

in writing and filed with the clerk of court not less than ten days prior to the

date set for trial, or on or before the third day following receipt of notice of

the date set for trial, whichever is later.

{¶ 7} As stated, the trial court deemed Bennett’s jury demand untimely because it

had not been filed ten days before the original trial date. However, when asked to

construe Crim.R. 23(A) in City of Tallmadge v. DeGraft-Biney, 39 Ohio St.3d 300, 530

N.E.2d 1310 (1988), the Ohio Supreme Court stated:

The time limits of Crim.R. 23(A) regarding the filing of a jury demand are to

be computed with respect to the last scheduled trial date. Where a jury

demand is not timely filed with respect to the originally scheduled trial date,

a continuance of the trial will renew the time within which to file a jury

demand. -4-

Id. at syllabus.

{¶ 8} In reaching its decision, the DeGraft-Biney court cited Dayton v. Wood, 2d

Dist. Montgomery No. 7001, 1981 WL 2820 (June 10, 1981). In Wood, the trial court

originally scheduled a trial for June 9, 1980. Thereafter, the public defender’s office filed

a notice of appearance. A written jury demand was filed on June 4, 1980. The trial

court denied the jury demand as untimely but continued the trial date. Ultimately, the

case was tried to the bench in September 1980. No further written jury demand was

filed.

{¶ 9} On appeal, we concluded that although the defendant’s written jury demand

was not filed ten days prior to the originally scheduled trial date, his request was timely

because it was filed “on or before the third day following receipt of notice” of the actual,

rescheduled, trial date. Id. at *2.

{¶ 10} In Bennett’s case, the trial was originally set for November 1, 2022.

Although the jury demand was not timely filed as to that trial date, it was filed “on or before

the third day following receipt of notice” of the actual trial date of November 3, 2022.

Thus, the trial court erred by denying Bennett a trial by jury.

{¶ 11} In coming to this conclusion, we reject the State’s reliance on State v.

Brown, 5th Dist. Coshocton No. 90-CA-25, 1991 WL 100409 (June 3, 1991). In Brown,

counsel, representing Brown regarding a first-degree misdemeanor, filed an appearance

of counsel, a motion to continue the already-scheduled trial date, and a motion for a jury

trial. The trial court overruled the motion for a jury trial as untimely under Crim.R. 23(A),

but the motion for continuance of the trial date was granted and a new trial date was set. -5-

Brown ultimately entered a no contest plea and was found guilty of the charged offense.

On appeal, Brown relied on DeGraft-Biney, 39 Ohio St.3d 300, 530 N.E.2d 1310, and

argued “that when the new, continued trial date was later set the request for jury trial was

rendered timely.” Brown at *1. The appellate court disagreed, stating that in DeGraft-

Biney, “an extant motion was rendered timely by the establishment of a continued trial

date prior to ruling thereupon.” Id. The Brown court concluded that “the trial court

overruled Brown’s motion for a jury trial, and no new motion for jury trial was filed so as

to be timely with respect to the continued trial date.” (Emphasis sic.) Id. Based upon

Brown, the State argues when the trial court “overruled” Bennett’s jury demand, the

“untimely request for a jury demand [became] ‘dead’ and [could not] be revived absent

the filing * * * of another written [jury] demand that [was] timely based upon the new trial

date.” The State’s reliance on Brown is misplaced.

{¶ 12} In DeGraft-Biney, a jury demand was filed, not a motion requesting a jury

trial as suggested by the Brown decision. This is consistent with Crim.R. 23(A), which

simply requires a defendant to file a jury demand. It seems the Brown court concluded

that, because a motion for a jury trial had been filed and overruled, there was not a jury

demand “extant” – that is, pending – when the continued trial date was set, making the

DeGraft-Biney decision inapplicable. If Brown is understood as the appellate court’s

making a distinction between a motion for a jury trial and a jury demand, this distinction

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Related

Columbus Checkcashers, Inc. v. Guttermaster, Inc.
2013 Ohio 5543 (Ohio Court of Appeals, 2013)
State v. Bacon, Unpublished Decision (11-23-2005)
2005 Ohio 6238 (Ohio Court of Appeals, 2005)
State v. Dixon
2016 Ohio 7438 (Ohio Court of Appeals, 2016)
State v. Hussein
2017 Ohio 5519 (Ohio Court of Appeals, 2017)
City of Mentor v. Giordano
224 N.E.2d 343 (Ohio Supreme Court, 1967)
State v. Stauffer
356 N.E.2d 724 (Ohio Supreme Court, 1976)
State v. Tate
391 N.E.2d 738 (Ohio Supreme Court, 1979)
City of Tallmadge v. DeGraft-Biney
530 N.E.2d 1310 (Ohio Supreme Court, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 274, 234 N.E.3d 629, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bennett-ohioctapp-2024.