State v. Coby

2025 Ohio 2192
CourtOhio Court of Appeals
DecidedJune 23, 2025
Docket24CA4114
StatusPublished
Cited by1 cases

This text of 2025 Ohio 2192 (State v. Coby) 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. Coby, 2025 Ohio 2192 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Coby, 2025-Ohio-2192.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT SCIOTO COUNTY

State of Ohio, : Case No. 24CA4114

Plaintiff-Appellee, : DECISION AND JUDGMENT ENTRY v. :

Willie L. Coby, : RELEASED 6/20/2025

Defendant-Appellant. :

______________________________________________________________________ APPEARANCES:

Willie Coby, Lancaster, Ohio, pro se appellant.

Shane A. Tieman, Prosecuting Attorney, and Jay Willis, Assistant Prosecuting Attorney, Portsmouth, Ohio, for appellee. ______________________________________________________________________ Hess, J.

{¶1} Willie L. Coby appeals from a judgment of the Scioto County Common Pleas

Court denying his “motion for lack of jurisdiction over the subject-matter,” which the court

treated as a petition for postconviction relief. Coby asserts one assignment of error, which

he phrases as a question: “Did the judge abuse his discretion when he denied the

appellant’s motion for lack of jurisdiction over the subject matter?” For the reasons which

follow, we overrule the assignment of error and affirm the judgment of the trial court as

modified to reflect dismissal of the petition.

I. PROCEDURAL HISTORY

{¶2} On May 17, 2022, the Scioto County grand jury indicted Coby on two counts

of trafficking in a fentanyl-related compound, first-degree felonies, in violation of R.C.

2925.03(A)(2) and (C)(9)(h), with major drug offender specifications; two counts of Scioto App. No. 24CA4114 2

possession of a fentanyl-related compound, first-degree felonies, in violation of R.C.

2925.11(A) and (C)(11)(g), with major drug offender specifications; and one count of

possessing criminal tools, a fifth-degree felony, in violation of R.C. 2923.24(A) and (C).

On September 21, 2022, the Scioto County grand jury issued a superseding indictment

which charged Coby with two counts of trafficking in cocaine, first-degree felonies, in

violation of R.C. 2925.03(A)(2) and (C)(4)(g), with major drug offender specifications; two

counts of possession of cocaine, first-degree felonies, in violation of R.C. 2925.11(A) and

(C)(4)(f); and one count of possessing criminal tools, a fifth-degree felony, in violation of

R.C. 2923.24(A) and (C).

{¶3} In February 2023, Coby executed a form in which he entered a plea of guilty

to one count of trafficking in cocaine, a first-degree felony, amended from a violation of

R.C. 2925.03(A)(2) and 2925.03(C)(4)(g) to a violation of R.C. 2925.03(A)(2) and

2925.03(C)(4)(f), and one count of possessing criminal tools, a fifth-degree felony, in

violation of R.C. 2923.24(A) and (C). The trial court accepted the plea. On May 31, 2023,

the court conducted a sentencing hearing. On June 9, 2023, the court issued a judgment

entry of sentence. Coby did not file a direct appeal.

{¶4} On October 18, 2024, Coby filed a “motion for lack of jurisdiction over the

subject-matter.” Coby asserted that the criminal jurisdiction of a common pleas court is

invoked pursuant to Crim.R. 7(A), which provides that all felonies shall be prosecuted by

indictment unless the defendant waives that right. He claimed the State failed to produce

a proper indictment, so the trial court lacked subject-matter jurisdiction over his criminal

case, and his judgment of conviction was void. Coby claimed the State allowed a trooper

to tell the grand jury that the substance at issue was fentanyl instead of having it tested Scioto App. No. 24CA4114 3

in a laboratory to see whether it was a drug, and if so, what type of drug. He claimed the

State knew the trooper’s information was false because four months after the original

indictment, a superseding indictment was issued which did not include any fentanyl-

related offenses and instead included cocaine-related offenses. He claimed the State’s

“clear act of malicious prosecution” violated his constitutional rights, and the superseding

indictment violated Crim.R. 7(D), which does not permit a court to amend an indictment

to change the name or identity of the crime charged. He asked the trial court to “reverse

and dismiss” his conviction.

{¶5} The trial court denied the motion. The court considered his motion a petition

for post-conviction relief, found it was untimely, and concluded Coby did not explain why

his petition was late or allege any factor which would let the court consider the late

petition. In addition, the court found that res judicata barred Coby’s claims and that he

had not shown substantive grounds for relief.

II. ASSIGNMENT OF ERROR

{¶6} Coby presents one assignment of error: “Did the judge abuse his discretion

when he denied the appellant’s motion for lack of jurisdiction over the subject matter?”

III. LAW AND ANALYSIS

{¶7} In his sole assignment of error, Coby asks whether the trial court abused its

discretion in denying his motion; his argument suggests the trial court should have

granted it. Coby asserts that “[a] court’s felony jurisdiction is invoked by the proper

indictment by the Grand jury of the County.” Coby claims the prosecutor secured the

original indictment by not presenting exculpatory evidence and using false information to

manipulate the grand jury. He suggests the trial court violated Crim.R. 7(D) by allowing Scioto App. No. 24CA4114 4

the superseding indictment to be filed. He also suggests the trial court violated Crim.R.

7(D) by amending one of the trafficking in cocaine offenses in the superseding indictment.

Coby asserts that “[i]t is well settled in Ohio that a void indictment makes that judgment

of conviction equally void for lack of jurisdiction of the subject matter.” He relies on State

v. Cimpritz, 158 Ohio St. 490 (1953), paragraph six of the syllabus, to support the position

that he can raise his indictment-related challenges in a collateral proceeding.

A. Subject-Matter Jurisdiction

{¶8} Subject-matter jurisdiction is “‘the constitutional or statutory power of a court

to adjudicate a particular class or type of case.’” State ex rel. Ogle v. Hocking Cty.

Common Pleas Court, 2023-Ohio-3534, ¶ 16, quoting State v. Harper, 2020-Ohio-2913,

¶ 23, citing Pratts v. Hurley, 2004-Ohio-1980, ¶ 11-12, 34. “‘“A court’s subject-matter

jurisdiction is determined without regard to the rights of the individual parties involved in

a particular case.”’” Id., quoting Harper at ¶ 23, quoting Bank of Am., N.A. v. Kuchta,

2014-Ohio-4275, ¶ 19 (“Kuchta”). “‘Rather, the focus is on whether the forum itself is

competent to hear the controversy.’” Id., quoting Harper at ¶ 23, citing 18A Wright, Miller

& Cooper, Federal Practice and Procedure, § 4428, at 6 (3d Ed. 2017) (“Jurisdictional

analysis should be confined to the rules that actually allocate judicial authority among

different courts”). “[A] court’s lack of subject-matter jurisdiction renders that court’s

judgment void ab initio.” Kuchta at ¶ 17, citing Pratts at ¶ 11. “The authority to vacate a

void judgment . . . constitutes an inherent power possessed by Ohio courts.” Patton v.

Diemer, 35 Ohio St.3d 68 (1988), paragraph four of syllabus. “[T]he issue of subject-

matter jurisdiction can be challenged at any time . . . .” Kuchta at ¶ 17, citing Pratts at ¶

11. “Whether a trial court had subject-matter jurisdiction is a question of law that we Scioto App. No. 24CA4114 5

review de novo.” Smith v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Horsley
2025 Ohio 5806 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2192, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-coby-ohioctapp-2025.