State v. Chambers

2024 Ohio 3341
CourtOhio Court of Appeals
DecidedAugust 30, 2024
DocketL-23-1068
StatusPublished
Cited by5 cases

This text of 2024 Ohio 3341 (State v. Chambers) 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. Chambers, 2024 Ohio 3341 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Chambers, 2024-Ohio-3341.]

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

State of Ohio Court of Appeals No. L-23-1068

Appellee/Cross-appellant Trial Court No. CR0202202751

v.

Bryan Chambers DECISION AND JUDGMENT

Appellant/Cross-appellee Decided: August 30, 2024

*****

Julia Bates, Lucas County Prosecuting Attorney, and Angela M. Zavac, Assistant Prosecuting Attorney, for appellee/cross-appellant.

Anthony J. Richardson, II, for appellant/cross-appellee.

***** MAYLE, J.

{¶ 1} Appellant/cross-appellee, Bryan Chambers, appeals the March 16, 2023

judgment of the Lucas County Court of Common Pleas sentencing him following his

conviction of felonious assault and kidnapping, claiming that the trial court improperly

excluded evidence that he was reasonably disciplining his son, there is insufficient

evidence to support his convictions, and the court should have merged his convictions at

sentencing. Appellee/cross-appellant, the state of Ohio, also challenges Chambers’s sentence because the trial court imposed a definite prison term for a qualifying second-

degree felony instead of the statutorily required indefinite prison term. Although the trial

court acted within its discretion by excluding reasonable parental discipline as a defense,

Chambers’s convictions are supported by sufficient evidence, are not against the manifest

weight of the evidence, and are not allied offenses of similar import, the trial court erred

by imposing a definite sentence for the felonious assault conviction, so we affirm in part,

reverse in part, and remand the case for resentencing.

I. Background and Facts

{¶ 2} Chambers was indicted on one count each of kidnapping in violation of R.C.

2905.01(A)(3), a first-degree felony, and felonious assault in violation of R.C.

2903.11(A)(1), second-degree felony.1 The charges arose from allegations that

Chambers took his son, V.L., out of school when he was not supposed to, put V.L. in the

back seat of his car with the child locks engaged so that the doors would not open from

the inside, drove V.L. to his house, and beat V.L., causing injuries including a fractured

wrist bone, petechiae from strangulation, and heavy bruising.

A. Pretrial issues

{¶ 3} Two pretrial motions are relevant to this appeal. First, Chambers filed a

request for a jury instruction on reasonable parental discipline that required the jury to

find him not guilty of felonious assault if it found that he was reasonably disciplining

1 He was also indicted on one count of domestic violence that was dismissed before trial.

2. V.L. at the time of the incident. In response, the state asked the court to deny

Chambers’s request because causing serious physical harm to a child—as required for a

felonious assault conviction—goes beyond the scope of reasonable parental discipline. It

also pointed out that the instruction was unnecessary as a matter of law because

Chambers would not be entitled to the instruction if the jury found that he caused serious

physical harm to V.L. and would be found not guilty if the jury found that he did not

cause serious physical harm to V.L.

{¶ 4} Second, the state filed a motion in limine to exclude the testimony of Shawn

Mahone Sr., who runs a behavior-modification boot camp program that V.L. attended in

2021. The state argued that V.L.’s interactions with Mahone were not relevant to the

events of October 7, 2022, and that any testimony Mahone could offer about V.L.’s

behavior months before the incident had no bearing on whether Chambers kidnapped and

assaulted V.L. In response, Chambers said that Mahone would testify about V.L.’s prior

“disciplinary behavior,” V.L.’s prior enrollment in the boot camp program, and

Chambers contacting him about a month before the incident to reenroll V.L. in the boot

camp. This would show that Chambers’s actions on October 7 constituted reasonable

parental discipline, and excluding Mahone’s testimony would prevent him from

presenting evidence of his affirmative defense.

{¶ 5} The trial court held a hearing on the parties’ motions. At the hearing,

Chambers argued that the context surrounding his actions on October 7 was important;

V.L.’s disciplinary issues, poor performance in school, and involvement in Mahone’s

3. program were all relevant to how Chambers handled things that day. He argued that,

although V.L. suffered a broken arm, there was no allegation that he intentionally broke

V.L.’s arm and the medical records indicated that there could be another explanation for

the break, so it was unlikely that the state could show that he intended to cause serious

physical harm. The fact that V.L. also had nonserious physical injuries, when combined

with the lack of intent, made the reasonable parental discipline instruction proper.

{¶ 6} In response, the state argued that case law does not support using reasonable

parental discipline as a defense to a charge of felonious assault. It took the position that

“if evidence is produced that there is serious physical harm, the [reasonable parental

discipline] instruction is not warranted.” It also pointed out that V.L.’s injuries were all

part of the same course of conduct, and V.L.’s broken wrist was not the only serious

physical harm that occurred during that course of conduct. Chambers also allegedly

strangled V.L., which the state believed was additional serious physical harm.

{¶ 7} Regarding Mahone’s testimony, the state argued that V.L.’s participation in

the boot camp was too far removed from the events of October 7, 2022—he was there

about 17 months before—and was not relevant to whether Chambers kidnapped or caused

serious physical harm to V.L. It also claimed that Chambers’s attempts to reenroll V.L.

in the program was nothing more than an inquiry (i.e., it was not evidence that V.L. was

enrolled in the program), which was also irrelevant to the charges against Chambers.

{¶ 8} The court denied Chambers’s request for the reasonable parental discipline

jury instruction. It determined that “[c]ausing serious physical harm to a child is by its

4. very nature unreasonable discipline and therefore, the defense of reasonable parental

discipline could never logically apply.” It also noted that there was no precedent for

using the instruction in a felonious assault case. The court granted the state’s motion to

preclude Mahone’s testimony. Although the court believed that his testimony would be

relevant to a reasonable parental discipline defense, as it stood, Mahone’s testimony

“would bolster a defense not available to . . .” Chambers, so the testimony was irrelevant

and inadmissible. The court clarified that the parties could present and discuss V.L.’s

discipline issues at trial; it was only excluding a witness with irrelevant testimony about

something that happened 17 months before the incident underlying this case.

B. Trial

1. State’s case

{¶ 9} Chambers’s case was tried to a jury in February 2023. The state presented

the testimony of V.L., the victim; Emily Johnson, the assistant principal at V.L.’s school;

Jeffrey Roberts, a security and resource officer at V.L.’s school; Jenae James, James’s

stepdaughter, and Elizabeth Starr, three of Chambers’s neighbors; Shaliah Lacy, V.L.’s

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 3341, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-chambers-ohioctapp-2024.