State v. Bulger

2023 Ohio 4004
CourtOhio Court of Appeals
DecidedNovember 3, 2023
DocketS-23-001
StatusPublished
Cited by6 cases

This text of 2023 Ohio 4004 (State v. Bulger) 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. Bulger, 2023 Ohio 4004 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Bulger, 2023-Ohio-4004.]

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

State of Ohio Court of Appeals No. S-23-001

Appellee Trial Court No. 22CR147

v.

Stephon Bulger DECISION AND JUDGMENT

Appellant Decided: November 3, 2023

*****

Beth A. Tischler, Sandusky County Prosecuting Attorney, and Alexis M. Otero, Assistant Prosecuting Attorney, for appellee.

Loretta Riddle, for appellant.

ZMUDA, J.

{¶ 1} This matter is before the court on appeal of the judgment of the Sandusky

County Court of Common Pleas, finding appellant, Stephon Bulger, guilty of the offense

of aggravated assault in violation of R.C. 2903.12(A)(1), a felony of the fourth degree,

imposing a prison term of 9 months, and granting 63 days of jail-time credit. For the

reasons that follow, we affirm. I. Facts and Procedural History

{¶ 2} On October 21, 2021, appellant went to the home of his friend, Tiffany

Smith, to help remove Smith’s boyfriend, J.J., from her home. Smith’s nephew, Steven

Webb, also came to his aunt’s aid. The three entered the home and found J.J. asleep in

Smith’s bed. A beating ensued, with appellant arguing Webb was the main assailant,

delivering a vicious beating until Smith determined the assault was sufficient. As a result

of the assault, J.J. sustained serious injuries.

{¶ 3} On February 18, 2022, appellant was charged by indictment with felonious

assault in violation of R.C. 2903.11(A)(1) and (D)(1)(a), a felony of the second degree.

A warrant issued for appellant’s arrest, and he was taken into custody several months

later.

{¶ 4} On July 22, 2022, appellant appeared with counsel for arraignment and

entered a plea of not guilty.

{¶ 5} On September 19, 2022, appellant withdrew his former not-guilty plea and

entered a plea of guilty to the amended offense of aggravated assault in violation of R.C.

2903.12(A)(1), a felony of the fourth degree. The trial court accepted the plea, found

appellant guilty, and referred the matter for a presentence investigation report.

{¶ 6} On December 28, 2022, the trial court held a sentencing hearing.

Appellant’s trial counsel argued in favor of community control, noting appellant’s claim

he did not actively participate in the beating and was disabled, with his blindness

indicating it unlikely that appellant had the ability to participate in the assault, despite his

2. guilty plea. The trial court considered the facts, and appellant’s criminal record that

included numerous community control violations, and found a community control

sanction was not appropriate. The trial court imposed a definite prison term of 9 months,

granting jail-time credit of 63 days “up to and including the date of sentencing and

excluding conveyance time.”

{¶ 7} This appeal followed.

II. Assignments of Error

{¶ 8} Bulger assigns three errors for appellate review, as follows:

1. Stephon Bulger received constitutionally ineffective assistance of

counsel when his trial counsel failed to pursue self defensne [sic.]

and/or defensne [sic.] of others resulting in Mr. Bulger failing to

make a knowingly, intelligently and voluntary plea.

2. The trial court errored by accepting Mr. Bulger’s plea without

ensuring that he was aware of his right to pursue self defensne [sic.]

and/or defensne [sic.] of others resulting in Mr. Bulger failing to

3. The trial court’s denial of jail time credit for any conveyance time, is

contrary to law.

III. Analysis

{¶ 9} Appellant’s first and second assignments of error concern the applicability

of self-defense or defense of others as a factor negating a knowing, intelligent, and

3. voluntary plea. His third assignment of error concerns proper jail time credit. For ease of

discussion, we address the first two assignments of error together, followed by

consideration of error concerning jail time credit.

A. Self-Defense

{¶ 10} Appellant argues he could have pursued self-defense or defense of others,

and his trial counsel’s failure to address this with appellant, prior to his plea, constituted

ineffective assistance of counsel and rendered his plea defective. The viability of

appellant’s self-defense claim is dispositive as to these assignments of error.

{¶ 11} Appellant argues his counsel was ineffective in failing to assert self-

defense, rendering his guilty plea unknowing, unintelligent, and involuntary. Appellant

entered a guilty plea, and while this waived all error regarding the state’s ability to prove

the elements of the offense, the claim for ineffective assistance of counsel was not

waived by virtue of the plea. State v. Combs, 6th Dist. Wood No. WD-20-003, 2021-

Ohio-982, ¶ 14, citing State v. Riddle, 2017-Ohio-1199, 88 N.E.3d 475, ¶ 26 (2d Dist.).

“[A] guilty plea waives all appealable errors, including claims of ineffective assistance of

counsel, except to the extent that the errors precluded the defendant from knowingly,

intelligently, and voluntarily entering his or her guilty plea.” Riddle at ¶ 26.

{¶ 12} To demonstrate ineffective assistance of counsel, appellant must show his

trial counsel’s performance was deficient, or below an objective standard of reasonable

representation, and he must show this deficient performance had a prejudicial effect, or

that there is “a reasonable probability that, but for counsel’s errors, the proceeding’s

4. result would have been different.” State v. Hale, 119 Ohio St.3d 118, 2008-Ohio-3426,

892 N.E.2d 864, ¶ 204, citing Strickland v. Washington, 466 U.S. 668, 687-688, 694, 104

S.Ct. 2052, 80 L.Ed.2d 674 (1984); State v. Bradley, 42 Ohio St.3d 136, 538 N.E.2d 373

(1989), paragraph two of the syllabus. In this case, appellant’s claimed error fails on both

prongs, as appellant does not demonstrate deficient performance by his trial counsel or

that a failure to explore the affirmative defense of self-defense resulted in prejudice.

{¶ 13} As to the first prong, appellant must demonstrate deficient performance by

demonstrating his trial counsel’s representation fell below an objective standard of

reasonable representation. Strickland at 668. Our scrutiny of counsel’s performance is

“highly deferential,” and we “indulge in a strong presumption that counsel’s conduct falls

within the wide range of reasonable professional assistance.” Bradley at 142, citing

Strickland at 689. As to the second prong, prejudice is shown by demonstrating that “but

for counsel’s unprofessional errors, the result of the proceeding would have been

different.” Id., citing Strickland at 694.

{¶ 14} To merit consideration of the affirmative defense of self-defense, appellant

first had “the burden of producing legally sufficient evidence of self-defense to trigger

the state’s duty to overcome that evidence.” State v. Messenger, 171 Ohio St.3d 227,

2022-Ohio-4562, 216 N.E.3d 653, ¶ 19. While the burden is not onerous, and may be

demonstrated with the state’s evidence, a claimant must satisfy this burden and present

evidence “that tends to support” a self-defense claim. State v. Baker, 2023-Ohio-241,

5.

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 4004, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bulger-ohioctapp-2023.