State v. Cioffi

2025 Ohio 423
CourtOhio Court of Appeals
DecidedFebruary 10, 2025
Docket8-24-36
StatusPublished

This text of 2025 Ohio 423 (State v. Cioffi) 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. Cioffi, 2025 Ohio 423 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Cioffi, 2025-Ohio-423.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT LOGAN COUNTY

STATE OF OHIO, CASE NO. 8-24-36 PLAINTIFF-APPELLEE,

v.

CARLOS M. CIOFFI, OPINION

DEFENDANT-APPELLANT.

Appeal from Logan County Common Pleas Court General Division Trial Court No. CR-23 06 0137

Judgment Affirmed in Part, Reversed in Part and Cause Remanded

Date of Decision: February 10, 2025

APPEARANCES:

Christopher Bazeley for Appellant

Nathan Yohey for Appellee Case No. 8-24-36

MILLER, J.

{¶1} Defendant-Appellant, Carlos Cioffi (“Cioffi”), appeals from the May

30, 2024 judgment of the Logan County Court of Common Pleas, following a jury

trial and sentencing resulting in convictions for four counts of domestic violence

and two counts of felonious assault. Cioffi argues the trial court erred in failing to

merge some of his convictions and in allowing the State to present evidence of his

prior conduct. For the reasons that follow, we agree with Cioffi regarding merger

and disagree with him regarding the evidence of his prior conduct. Accordingly,

the trial court’s judgment is reversed with respect to its failure to merge Counts 2

and 3 and with respect to its failure to merge Counts 4 and 5, and we remand the

matter for the limited purpose of resentencing Cioffi in accordance with this

opinion. In all other respects, the trial court’s judgment is affirmed.

I. FACTS AND PROCEDURAL HISTORY

{¶2} Mindy Cioffi (“Mindy”) was married to Cioffi during all relevant times

and is the alleged victim of the offenses. On June 14, 2023, Cioffi was indicted on

six charges. Counts 1, 3, 5, and 6 each charged Cioffi with committing domestic

violence, first-degree misdemeanors in violation of R.C. 2919.25(A). These four

charges stemmed from alleged incidents on January 14, March 2, March 12, and

April 22, 2023. Counts 2 and 4 both charged Cioffi with committing felonious

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assault, second-degree felonies in violation of R.C. 2903.11(A)(1). These two

charges stemmed from alleged incidents on March 2 and March 12, 2023—the same

dates as the domestic violence charges in Counts 3 and 5, respectively.

{¶3} The case proceeded to trial on April 24-25, 2024. The witnesses at trial

included a police sergeant from the Bellefontaine Police Department, Mindy, and

expert witness Deborah Brownlee (“Brownlee”). Most of the numerous exhibits

admitted at trial were photos of Mindy’s injuries allegedly inflicted by Cioffi. After

deliberation, the jury found Cioffi guilty of all six charges.

{¶4} The trial court held a sentencing hearing on May 30, 2024. The trial

court sentenced Cioffi to 180 days in jail on each of the four domestic violence

counts, four to six years in prison on Count Two for felonious assault, and four years

in prison on Count Four for felonious assault. The trial court ordered all six

sentences to be served concurrently for an aggregate total of four to six years in

prison. This appeal followed.

II. ASSIGNMENTS OF ERROR

{¶5} Cioffi raises two assignments of error for our review:

First Assignment of Error

The trial court erred when it failed to merge Cioffi’s convictions on Counts Two and Three, and, separately, his convictions on Counts Four and Five.

-3- Case No. 8-24-36

Second Assignment of Error

The trial court erred when it allowed the State to present evidence of Cioffi’s prior conduct to the jury.

III. DISCUSSION

A. First Assignment of Error

{¶6} In the first assignment of error, Cioffi argues that the domestic violence

and felonious assault offenses that occurred on March 2, 2023 (i.e., Counts 2 and 3)

should have merged. He also argues that the domestic violence and felonious

assault offenses that occurred on March 12, 2023 (i.e., Counts 4 and 5) should have

merged. Notably, the State does not contest this assignment of error.

{¶7} “We review de novo whether certain offenses should be merged as

allied offenses under R.C. 2941.25.” State v. Bailey, 2022-Ohio-4407, ¶ 6. The

defendant bears the burden of establishing he or she is entitled to the protection

provided by R.C. 2941.25 against multiple punishments for a single criminal act.

State v. Washington, 2013-Ohio-4982, ¶ 18.

{¶8} When a defendant’s conduct supports multiple offenses, courts apply

the allied offenses analysis in R.C. 2941.25 to determine if the offenses merge or if

the defendant may be convicted of separate offenses. State v. Cass, 2024-Ohio-

2614, ¶ 19 (3d Dist.). The statute states:

(A) Where the same conduct by defendant can be construed to constitute two or more allied offenses of similar import, the indictment or information may contain counts for all such offenses, but the defendant may be convicted of only one.

-4- Case No. 8-24-36

(B) Where the defendant’s conduct constitutes two or more offenses of dissimilar import, or where his conduct results in two or more offenses of the same or similar kind committed separately or with a separate animus as to each, the indictment or information may contain counts for all such offenses, and the defendant may be convicted of all of them.

R.C. 2941.25. The Supreme Court of Ohio clarified certain aspects of this statute

in State v. Ruff, 2015-Ohio-995. The court’s syllabus held:

1. In determining whether offenses are allied offenses of similar import within the meaning of R.C. 2941.25, courts must evaluate three separate factors—the conduct, the animus, and the import.

2. Two or more offenses of dissimilar import exist within the meaning of R.C. 2941.25(B) when the defendant’s conduct constitutes offenses involving separate victims or if the harm that results from each offense is separate and identifiable.

3. Under R.C. 2941.25(B), a defendant whose conduct supports multiple offenses may be convicted of all the offenses if any one of the following is true: (1) the conduct constitutes offenses of dissimilar import, (2) the conduct shows that the offenses were committed separately, or (3) the conduct shows that the offenses were committed with separate animus.

Id. at syllabus.

{¶9} The domestic violence statute provides that “[n]o person shall

knowingly cause or attempt to cause physical harm to a family or household

member.” R.C. 2919.25(A). The felonious assault statute prohibits someone from

knowingly causing “serious physical harm to another.” R.C. 2903.11(A)(1).

{¶10} Based on our review of the record, we agree with Cioffi that the

domestic violence and felonious assault offenses on March 2, 2023 (i.e., Counts 2

-5- Case No. 8-24-36

and 3) should have merged and the domestic violence and felonious assault offenses

on March 12, 2023 (i.e., Counts 4 and 5) should have merged. Based on Mindy’s

testimony, the March 2, 2023 incident consisted of a single act by Cioffi (pushing

her down the porch stairs), was committed with a single animus, and resulted in the

same harm. The same is true for the March 12, 2023 incident (single punch to face).

{¶11} Accordingly, Cioffi’s first assignment of error is sustained. The trial

court’s judgment of sentence with respect to Counts 2 and 3 and with respect to

Counts 4 and 5 is reversed, and this cause is remanded for the limited purpose of

resentencing. State v. Trigg, 2016-Ohio-2752, ¶ 12-15 (2d Dist.) (trial court

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2025 Ohio 423, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cioffi-ohioctapp-2025.