State v. Coker

2025 Ohio 2656
CourtOhio Court of Appeals
DecidedJuly 29, 2025
DocketWD-22-054
StatusPublished

This text of 2025 Ohio 2656 (State v. Coker) 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. Coker, 2025 Ohio 2656 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Coker, 2025-Ohio-2656.]

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

State of Ohio Court of Appeals No. WD-22-054

Appellee Trial Court No. 21 CR 180

v.

Stephen Coker, Jr. DECISION AND JUDGMENT

Appellant Decided: July 29, 2025

*****

Paul A. Dobson, Wood County Prosecuting Attorney, David T. Harold, Chief Assistant Prosecuting Attorney, and, James A. Hoppenjans, for appellee.

Felice Harris and Kathleen Evans, for appellant.

***** SULEK, P.J.

{¶ 1} This matter is before the court on remand from the Supreme Court of Ohio

following the court’s reversal of our decision in State v. Coker, 2023-Ohio-4339 (6th

Dist.). See State v. Coker, 2025-Ohio-2051. The Supreme Court of Ohio’s judgment

orders that the court rule on Coker’s two remaining assignments of error presented in his

direct appeal. I. Facts and Procedural History

{¶ 2} An overview of the facts is as follows. Coker was indicted on three counts

of rape involving his wife, S.O. Coker, 2025-Ohio-2051, at ¶ 6. The matter proceeded to

a jury trial where S.O. testified regarding “date nights” where she and Coker engaged in

consensual and nonconsensual sexual activity. Id. at ¶ 7. The jury convicted Coker on

all three counts. Id. at ¶ 8. On direct appeal, this court reversed Coker’s convictions

finding insufficient evidence of sexual conduct during the periods charged in the

indictment. Id. at ¶ 9. The Supreme Court of Ohio reversed finding that jury could have

reasonably inferred that S.O.’s use of the term “have sex,” and similar, meant vaginal

intercourse and penetration. Id. at ¶ 26.

{¶ 3} Additional case history and facts are detailed in our prior decision and will

be referenced only when necessary.

II. Assignments of Error

{¶ 4} Coker’s remaining assignments of error are as follows:

Second Assignment of Error: Stephen Coker was denied the effective assistance of counsel guaranteed by the Sixth Amendment to the United States Constitution and Article I, Section 10 of the Ohio Constitution.

Third Assignment of Error: Stephen Coker was denied his constitutional rights to due process and a fair trial when the State engaged in prosecutorial misconduct.

2. III. Analysis

A. Reagan Tokes Law

{¶ 5} In Coker’s second assignment of error, he argues that trial counsel

ineffectively failed to challenge the Reagan Tokes Law, specifically R.C. 2967.271, as

violative of the separation-of-powers doctrine and on due process grounds.

{¶ 6} To prevail on an ineffective assistance of counsel claim, Coker must satisfy

the two-prong test set forth in Strickland v. Washington, 466 U.S. 668, 687-688, 694

(1984). That is, Coker must show (1) “that his counsel’s representation fell below an

objective standard of reasonableness,” and (2) “that there is a reasonable probability that,

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

different.” Id.

{¶ 7} In State v. Hacker, 2023-Ohio-2535, the Supreme Court of Ohio rejected

facial constitutional challenges to the Regan Tokes Law, including those raised by Coker.

As to the separation-of-powers doctrine, the court determined that the Ohio Department

of Rehabilitation and Correction’s (DRC) ability to rebut the minimum prison term

presumption was not in excess of its authority and did not impinge on the trial court’s

sentencing discretion. Id. at ¶ 25. The court also determined that the law did not violate

an offender’s due process rights. Under the void-for-vagueness doctrine, the court

concluded that the DRC’s discretion to extend incarceration beyond the minimum term

did not demonstrate a facial challenge to the law, only that it may be vague as applied.

Id. at ¶ 34. The court further determined that the law did not impinge on an offender’s

3. procedural due process rights because a hearing is provided before the DRC maintains his

incarceration. Id. at ¶ 39.

{¶ 8} Both prior to and following Hacker, this court has consistently rejected

constitutional challenges to the Reagan Tokes Law. See State v. Maddox, 2022-Ohio-

1350, ¶ 7 (6th Dist.); State v. Stenson, 2022-Ohio-2072, ¶ 35 (6th Dist.); State v.

Fenderson, 2023-Ohio-2903, ¶ 62 (6th Dist.). Had Coker preserved the issue in the trial

court on review, his claims would have been found meritless, thus, counsel was not

ineffective. Coker’s second assignment of error is not well-taken.

B. Prosecutorial Misconduct

{¶ 9} Coker’s third assignment of error claims prosecutorial misconduct in

comments made by the State during opening and closing arguments. “‘The two-fold test

for prosecutorial misconduct is whether the prosecutor’s conduct at trial was improper

and whether it prejudicially affected the substantial rights of the defendant.’” State v.

Carswell, 2023-Ohio-4574, ¶ 42, (6th Dist.), quoting State v. Holbrook, 2015-Ohio-4780,

¶ 32 (6th Dist.), citing State v. Lott, 51 Ohio St.3d 160, 165 (1990). “‘Important

considerations are whether the misconduct was an isolated incident or a protracted series

of improper arguments, whether the defendant objected, whether curative instructions

were given, and whether the evidence of guilt was overwhelming.’” State v. Norales-

Martinez, 2018-Ohio-4356, ¶ 32 (6th Dist.), quoting State v. Oviedo, 1997 WL 525087,

*2 (6th Dist. Aug. 15, 1997).

{¶ 10} Coker first claims that the trial court abused its discretion in denying his

motion for a mistrial based on the unduly prejudicial and outcome determinative

4. comments made by the State during its opening arguments. Specifically, the prosecutor’s

comments relating to three prior instances of sexual abuse against S.O. which provide:

And [S.O.] is going to tell you about her history, painful history, how she was sexually abused by her biological father when she was a young girl, how she was raped by three men when she was sixteen, and how she already survived one sexually abusive marriage prior to meeting the defendant.

The next morning defense counsel moved for a mistrial or dismissal contending that the

prejudicial statements were barred by the Rape Shield Law and were elicited to gain

sympathy for S.O. The State countered that the statements evidence S.O.’s state of mind

and reason for staying in an abusive relationship. The court ultimately denied the motion

but prohibited the introduction of any testimony as to unrelated prior sexual assault or

violence against S.O.

{¶ 11} A trial court’s decision denying a mistrial is reviewed under an abuse of

discretion standard. State v. Durst, 2020-Ohio-607, ¶ 46 (6th Dist.); State v. Sage, 31

Ohio St.3d 173, 182 (1987). Mistrials should be granted “only when justice requires and

a fair trial is no longer possible.” State v. Madison, 2020-Ohio-3735, ¶ 196, citing State

v. Cepec, 2016-Ohio-8076, ¶ 89.

{¶ 12} When the motion for a mistrial alleges prosecutorial misconduct, “‘a

reviewing court must undertake a due process analysis to determine whether the conduct

of the prosecutor deprived the defendant of his or her due process right to a fair trial.’”

State v. Gomez, 2019-Ohio-576, ¶ 59 (6th Dist.), quoting State v. Saunders, 98 Ohio

App.3d 355, 358 (6th Dist.1994).

5.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Holbrook
2015 Ohio 4780 (Ohio Court of Appeals, 2015)
State v. Saunders
648 N.E.2d 587 (Ohio Court of Appeals, 1994)
State v. Boles, L-07-1255 (2-6-2009)
2009 Ohio 512 (Ohio Court of Appeals, 2009)
State v. Steed
2016 Ohio 8088 (Ohio Court of Appeals, 2016)
State v. Cepec (Slip Opinion)
2016 Ohio 8076 (Ohio Supreme Court, 2016)
State v. Carter
2017 Ohio 1328 (Ohio Court of Appeals, 2017)
State v. Hopkins
2018 Ohio 1864 (Ohio Court of Appeals, 2018)
State v. Norales-Martinez
2018 Ohio 4356 (Ohio Court of Appeals, 2018)
State v. Gomez
2019 Ohio 576 (Ohio Court of Appeals, 2019)
State v. Durst
2020 Ohio 607 (Ohio Court of Appeals, 2020)
State v. Madison (Slip Opinion)
2020 Ohio 3735 (Ohio Supreme Court, 2020)
State v. Roby
2022 Ohio 223 (Ohio Court of Appeals, 2022)
State v. McAlpin
2022 Ohio 1567 (Ohio Supreme Court, 2022)
State v. Stenson
2022 Ohio 2072 (Ohio Court of Appeals, 2022)
State v. Clayton
402 N.E.2d 1189 (Ohio Supreme Court, 1980)
State v. Smith
470 N.E.2d 883 (Ohio Supreme Court, 1984)
State v. Sage
510 N.E.2d 343 (Ohio Supreme Court, 1987)
State v. Lott
555 N.E.2d 293 (Ohio Supreme Court, 1990)
State v. Ballew
667 N.E.2d 369 (Ohio Supreme Court, 1996)

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2025 Ohio 2656, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-coker-ohioctapp-2025.