State v. Bobo

2022 Ohio 3555, 198 N.E.3d 580
CourtOhio Court of Appeals
DecidedOctober 6, 2022
Docket111362
StatusPublished
Cited by3 cases

This text of 2022 Ohio 3555 (State v. Bobo) 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. Bobo, 2022 Ohio 3555, 198 N.E.3d 580 (Ohio Ct. App. 2022).

Opinion

[Cite as State v. Bobo, 2022-Ohio-3555.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 111362 v. :

VICTOR BOBO, :

Defendant-Appellant. : _______________________________________

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED IN PART, REVERSED IN PART, AND REMANDED RELEASED AND JOURNALIZED: October 6, 2022 ________________________________________

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-21-666312-B _________________________________________

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Luke Habermehl, Assistant Prosecuting Attorney, for appellee.

The Law Office of Jaye M. Schlachet, Jaye M. Schlachet, and Eric M. Levy, for appellant.

EMANUELLA D. GROVES, J.:

Defendant-appellant Victor Bobo (“Bobo”) appeals his conviction and

sentence after pleading guilty to one count of felony two drug trafficking. For the following reasons, we affirm in part, reverse in part, and remand for further

proceedings.

Procedural and Factual History

On January 14, 2022, Bobo was indicted for drug trafficking cocaine in

an amount exceeding 27 grams but less than 100 grams, a felony of the first degree

(Count 1); possession of cocaine, a felony of the first degree (Count 2); and

possession of criminal tools, a felony of the fifth degree (Count 3). Bobo also had

three other cases before the court as follows: Cuyahoga C.P. No. CR-21-633725-A:

receiving stolen property, a felony of the fourth degree; Cuyahoga C.P. No. CR-21-

664669: robbery a felony of the third degree and grand theft a felony of the fourth

degree; and Cuyahoga C.P. No. CR-22-666766: abduction, a felony of the third

degree; domestic violence, a felony of the fourth degree; and resisting arrest, a

misdemeanor of the second degree.

On March 2, 2022, the court conducted a pretrial. Prior to that date,

Bobo’s counsel had asked the court to review his record for a possible community-

control sanction. The court informed Bobo that, after a review of his record if Bobo

reached a plea agreement, a prison term would be imposed. The court noted Bobo’s

lengthy criminal history and his four new cases from September 2021 to February

2022. Based on those facts alone, the trial court felt it would be inappropriate to

impose a community-control sanction.

After further discussion, the trial court adjourned until the afternoon

session to allow Bobo to discuss the case with his attorney. On returning to the record, Bobo accepted a plea deal and pleaded guilty to Count 1 as amended to a

felony of the second degree.1 The state dismissed the remaining charges on that

indictment. During the plea colloquy, the trial court advised Bobo that the sentence

required mandatory prison time. However, the trial court also advised Bobo that he

would be entitled to earn good-time credit and could reduce his term by 15 percent.

After accepting Bobo’s plea, the trial court proceeded immediately to

sentencing. Bobo was sentenced to a minimum indefinite sentence of three years to

a maximum possible term of four and one-half years.2 After the trial court

concluded sentencing, but before the case was adjourned, Bobo’s attorney

questioned whether he was eligible for good-time credit on a mandatory prison

term. The trial court indicated that the legislature is silent as to whether a defendant

is eligible for early release under S.B. 201.

Bobo now appeals assigning the following errors for our review.

Assignment of Error No. 1

The trial court erred when it found appellant’s plea was voluntary, knowing and intelligent and that he was aware of the maximum penalty involved where at the time of his change of plea he was given inaccurate information about prison reduction where the trial court imposed a mandatory prison sentence.

Assignment of Error No. 2

Appellant’s indefinite sentence imposed under the Reagan Tokes sentencing scheme violates appellant’s rights under the United States Constitution applied to the state of Ohio through the Fourteenth

1 Bobo also pleaded guilty to the grand theft charge as amended to a felony of the fifth degree and the domestic violence and resisting arrest charges.

2 Bobo was sentenced to credit for time served on his other cases. Amendment and the Ohio Constitution as it denies appellant due process of law; violates the Sixth Amendment right to a jury trial; violates the separation of powers doctrine; does not provide fair warning of the dictates of the statute to ordinary citizens; and the statute conferred too much authority to the Ohio Department of Rehabilitation and Correction (ODRC).

Assignment of Error No. 3

Appellant’s sentence is contrary to law where the trial court failed to comply with the required notices contained in R.C. 2929.19(B)(2)(c) when imposing sentence.

Law and Analysis

For ease of discussion, we will examine the assignments of error out of

order, when necessary. In the first assignment of error, Bobo argues that the trial

court erred when it found his guilty plea was voluntary, knowing, and intelligent

where the court informed him, incorrectly, that he was entitled to good-time credit

on a mandatory prison term. The state filed a notice of conceded error as to this

assignment of error pursuant to Loc.App.R. 16(B).

Bobo essentially argues that the trial court’s error violated Crim.R.

11(C)(2)(a), which states that a trial court

“shall not accept a plea of guilty * * * without first addressing the defendant personally * * * and: Determining that the defendant is making the plea voluntarily, with understanding of the nature of the charges and of the maximum penalty involved, and, if applicable, that the defendant is not eligible for probation or for the imposition of community control sanctions at the sentencing hearing.

Bobo argues that such an error is sufficient to warrant vacating his plea

and remanding the case back to the trial court. Alternatively, Bobo suggests the

Reagan Tokes Law, S.B. 201, might allow for good-time credit on a mandatory sentence. If so, Bobo argues, his first assignment of error is moot. We will address

Bobo’s arguments in this assignment of error in turn.

Preliminarily, a no-contest or guilty plea must be knowing,

intelligent, and voluntary because it involves a waiver of constitutional rights. State

v. Dangler, 162 Ohio St.3d 1, 2020-Ohio-2765, 164 N.E.3d 286, ¶ 10, citing Parke v.

Raley, 506 U.S. 20, 28-29, 113 S.Ct. 517, 121 L.Ed.2d 391 (1992); State v. Clark, 119

Ohio St.3d 239, 2008-Ohio-3748, 893 N.E.2d 462, ¶ 25. “If the plea was not made

knowingly, intelligently, and voluntarily, enforcement of the plea is

unconstitutional.” Id.

The requirements of an acceptable plea are codified in Ohio under

Crim.R. 11, and it includes constitutional and nonconstitutional elements. The rule

is intended to ensure “‘an adequate record on review by requiring the trial court to

personally inform the defendant of his rights and the consequences of his plea and

determine if the plea is understandingly and voluntarily made.’” Id. at ¶ 11, quoting

State v. Stone, 43 Ohio St.2d 163, 168, 331 N.E.2d 411 (1975).

No magic words are required to establish compliance with

Crim.R.

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Bluebook (online)
2022 Ohio 3555, 198 N.E.3d 580, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bobo-ohioctapp-2022.