State v. Bolden

2025 Ohio 2010
CourtOhio Court of Appeals
DecidedJune 5, 2025
Docket114504
StatusPublished

This text of 2025 Ohio 2010 (State v. Bolden) 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. Bolden, 2025 Ohio 2010 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Bolden, 2025-Ohio-2010.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 114504 v. :

MARVIER BOLDEN, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND REMANDED RELEASED AND JOURNALIZED: June 5, 2025

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-24-690050-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Krystal Hyojong Lee, Assistant Prosecuting Attorney, for appellee.

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

DEENA R. CALABRESE, J.:

Defendant-appellant Marvier Bolden, indicted in connection with an

aggravated robbery and a later police chase, entered guilty pleas to 3 of 12 counts.

The trial court sentenced appellant to an aggregate prison term of 60-78 months, plus restitution. Appellant now appeals, challenging several aspects of his

sentencing. Finding merit to the appeal, we reverse and remand for further

proceedings consistent with this opinion.

I. Factual and Procedural History

On January 7, 2024, appellant, a juvenile, entered a Lyft ride-sharing

vehicle with another male and brandished a firearm. The driver exited, after which

appellant took control of the vehicle and drove away. The following day, January 8,

2024, Cuyahoga Metropolitan Housing Authority officers spotted the stolen vehicle

and began chase. Appellant sped away, making several quick turns in the stolen car.

The pursuit lasted some ten minutes, with appellant ultimately exiting the still-

running vehicle and fleeing on foot. The vehicle came to a stop after it crashed into

a police cruiser. Police finally cornered and apprehended appellant.

A complaint was initially filed against appellant in juvenile court, and

the State sought a mandatory bindover to common pleas court. On March 26, 2024,

the Cuyahoga County Grand Jury returned a 12-count indictment charging

appellant with multiple felonies and misdemeanors, several with one- and three-

year firearm specifications attached under R.C. 2941.141(A) and 2941.145(A).

Appellant entered into a plea agreement, and on August 19, 2024, he pleaded guilty

to three counts, specifically:

Count 1, aggravated robbery, a felony of the first degree in violation of R.C. 2911.01(A)(1), with a one-year firearm specification;

Count 5, having weapons while under disability, a felony of the third degree in violation of R.C. 2923.13(A)(2); and Count 7, failure to comply with the order or signal of a peace officer, a felony of the third degree in violation of R.C. 2921.331(B).

The trial court sentenced appellant on September 30, 2024. On

Count 1, it imposed a mandatory prison term of 12 months on the one-year firearm

specification to be served prior to and consecutive to the underlying offense, in

which it imposed a minimum prison term of 36 months and a maximum of 60

months, to be served consecutively with all other counts. On Count 5, it imposed a

prison term of 36 months, to be run concurrently with all counts. Finally, on

Count 7, it imposed a prison term of 12 months, to be served consecutively with all

other counts.

II. Analysis

Appellant raises a single assignment of error for our review:

The trial court erred and imposed a prison sentence which was contrary to law and not supported by the record where the trial court failed to consider a community control sanction and failed to find the required sentencing factors specific to an offense of failure to comply pursuant to R.C. 2921.331(C)(5)(b) and where its journal entry of sentence does not properly reflect what occurred at the actual sentencing hearing.

Appellant divides his assignment of error into four distinct App.R.

16(A)(4) issues presented for review, with each issue essentially parsing out and

arguing a discrete error. We address them accordingly.

A. Issues 1 and 2 — R.C. 2921.331(C)(5)(b) Factors and Community Control

We address appellant’s first two arguments together. He frames the

issues as follows: Whether the record is unsupported or otherwise contains facts which would permit the trial court to consider and whether the trial court did consider the factors in R.C. 2921.331(C)(5)(b) prior to imposing sentence upon appellant for count seven, failure to comply with the order or signal of a peace officer.

Whether the trial court properly considered the possibility of a community control sanction prior to imposing what it referred to as a mandatory prison sentence.

R.C. 2953.08(G)(2) governs an appellate court’s review of a trial court’s

sentence. Pursuant to the statute, “‘an appellate court may vacate or modify a felony

sentence on appeal only if it determines by clear and convincing evidence that the

record does not support the trial court’s findings under relevant statutes or that the

sentence is otherwise contrary to law.’” State v. Evans, 2021-Ohio-1411, ¶ 12 (8th

Dist.), quoting State v. Marcum, 2016-Ohio-1002, ¶ 1. As this court has previously

stated:

A sentence is not clearly and convincingly contrary to law “where the trial court considers the purposes and principles of sentencing under R.C. 2929.11 as well as the seriousness and recidivism factors listed in R.C. 2929.12, properly applies post-release control, and sentences a defendant within the permissible statutory range.”

State v. Thompson, 2018-Ohio-1393, ¶ 7 (8th Dist.), quoting State v. A.H., 2013-

Ohio-2525, ¶ 10 (8th Dist.). See also Evans at ¶ 12. Furthermore, while “[t]he record

must indicate that the trial court considered all relevant factors required by R.C.

2929.11 and 2929.12,” the trial court “has no obligation to state reasons to support

its findings.” Evans at ¶ 13, citing State v. Bonnell, 2014-Ohio-3177, syllabus. This

is because R.C. 2929.11 and 2929.12 “are not fact-finding statutes.” State v. Seith,

2016-Ohio-8302, ¶ 12 (8th Dist.), citing State v. Keith, 2016-Ohio-5234, ¶ 11 (8th Dist.). “[T]he court is not required to use particular language or make specific

findings on the record regarding its consideration of those factors.” Id. at ¶ 11.

Indeed, “[t]rial courts . . . are not required to make factual findings on the record

under R.C. 2929.11 or 2929.12” even “before imposing the maximum sentence.”

State v. Gohagan, 2019-Ohio-4070, ¶ 21 (8th Dist.), citing State v. Kronenberg,

2015-Ohio-1020, ¶ 27 (8th Dist.).

Instead, “[c]onsideration of the factors is presumed unless the

defendant affirmatively shows otherwise.” Seith at ¶ 12, citing Keith at ¶ 11. “[A]

trial court’s statement in its sentencing journal entry that it considered the required

statutory factors alone is enough to fulfill its obligations under R.C. 2929.11 and

2929.12.” Seith at ¶ 12. See also Evans at ¶ 17, citing Kronenberg at ¶ 27.

Appellant’s arguments with respect to the trial court’s consideration

of community-control sanctions are somewhat confusing. It is unclear from the

assignment of error whether appellant is arguing the trial court should have made a

more detailed record with respect to the possibility of community-control sanctions

as to both Count 1 (aggravated robbery, a felony of the first degree) and Count 7

(failure to comply, a felony of the third degree), or just with respect to Count 7. The

sole assignment of error mentions “community control” without referencing a

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Related

State v. Bonnell (Slip Opinion)
2014 Ohio 3177 (Ohio Supreme Court, 2014)
State v. Marcum (Slip Opinion)
2016 Ohio 1002 (Ohio Supreme Court, 2016)
State v. Whitfield, 90245 (6-26-2008)
2008 Ohio 3145 (Ohio Court of Appeals, 2008)
State v. Keith
2016 Ohio 5234 (Ohio Court of Appeals, 2016)
State v. Seith
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2025 Ohio 2010, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bolden-ohioctapp-2025.