State v. Cunningham

CourtOhio Court of Appeals
DecidedMay 6, 2026
DocketCT2025-0099
StatusPublished

This text of State v. Cunningham (State v. Cunningham) 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. Cunningham, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Cunningham, 2026-Ohio-1643.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT MUSKINGUM COUNTY, OHIO

STATE OF OHIO Case No. CT2025-0099

Plaintiff – Appellee Opinion And Judgment Entry

-vs- Appeal from the Muskingum County Court of Common Pleas, Case No. CR2025-0391 DONALD L. CUNNINGHAM Judgment: Affirmed

Defendant - Appellant Date of Judgment Entry: May 6, 2026

BEFORE: William B. Hoffman, Robert G. Montgomery, and Kevin W. Popham, Judges

APPEARANCES: Joseph A. Palmer for Plaintiff-Appellee; Christopher Bazeley, for Defendant-Appellant

OPINION

Popham, J.,

{¶1} Appellant Donald Cunninhgam appeals the judgment entered by the

Muskingum County Court of Common Pleas following a jury trial. Appellee is the State

of Ohio. For the reasons below, we affirm.

Facts & Procedural History

{¶2} Cunningham was indicted on the following counts: strangulation, in

violation of R.C. 2903.18(B)(2), a felony of the third degree, kidnapping, in violation of

R.C. 2905.01(A)(2), a felony of the first degree, abduction, a violation of R.C.

2905.02(A)(2), a felony of the third degree, tampering with evidence, in violation of R.C. 2921.12(A)(1), a felony of the third degree, and obstructing official business, in violation

of R.C. 2921.31(A), a felony of the fifth degree.

{¶3} On July 29, 2025, a jury trial commenced from which the following facts are

adduced.

{¶4} Cunninghan and T.M. lived together for approximately three years but were

not romantically involved. T.M. testified that the occupants of the home used

methamphetamines several times per week. She stated that, during a verbal argument,

Cunningham complained that she would not have sex with him. T.M. testified that, as the

argument escalated, Cunningham grabbed her, covered her mouth and nose, punched her

in the head, and chased her downstairs after she had broken free. He then allegedly

prevented her from leaving by engaging the deadbolt and threatening to kill her. T.M. ran

upstairs, escaped through a window, fled to a neighbor’s house, and called 911.

{¶5} Police attempted to locate Cunningham, who testified that, although he was

not hiding from the police, he knew police were looking for him, and he was “trying to

avoid” them. When police apprehended Cunningham, they asked to see his phone to

obtain video footage from cameras in the home. Before handing the phone over to police,

Cunningham performed a factory reset - deleting all data off the phone.

{¶6} Unbeknownst to police, the phone, which was a new, different phone than

Cunnigham possessed at the time of the assault, Cunningham provided never contained

the relevant video. Cunningham had obtained a new phone after learning police were

looking for him, fearing the police would “ping” his old phone. Cunningham admitted he

knew police were seeking the videos and acknowledged that he lied to a detective by

stating the (new) phone, which he reset, did not contain the videos. He also failed to

disclose the existence of a second phone. {¶7} Cunningham further testified that he attempted to provoke police into

shooting him because he “wanted to die,” and he did not comply with officers’ instructions

during his arrest. He admitted that his conduct delayed the officers and delayed his

arrest. Defense counsel asked Cunningham - “and so if you were to learn that delaying an

officer in the performance of their duties without privilege to do so and creating a risk of

physical harm to somebody was a felony called obstructing official business, you would

agree that you committed that felony, right” – to which Cunningham responded, “right.”

{¶8} The jury found Cunningham not guilty of strangulation, kidnapping, and

abduction but guilty of tampering with evidence and obstruction of official business. The

jury also found that the obstruction offense created a risk of physical harm to

Cunningham.

{¶9} With the parties’ consent, the trial court proceeded immediately to

sentencing. The State requested an aggregate prison term of four years, citing

Cunningham’s criminal history, including aggravated burglary (1993), misdemeanor

assault (2023), violation of a protection order (2022), and misdemeanor domestic

violence (2021). Defense counsel requested a sentence of eighteen to twenty-four months

in prison.

{¶10} At the sentencing hearing, the trial court emphasized that Cunningham

worsened the situation by lying to police and deleting or concealing evidence. The court

also specifically noted that Cunningham’s attempt to provoke police into shooting him

was serious, and created a dangerous situation for himself and others in the

neighborhood.

{¶11} In an August 1, 2025, judgment entry, the trial court stated it considered the

record, all statements, the principles and purposes of sentencing contained in R.C. 2929.11, and the balance of seriousness and recidivism factors under R.C. 2929.12. The

trial court sentenced Cunningham to a stated prison term of 36 months in prison on the

tampering with evidence count, and a stated prison term of 12 months in prison on the

obstructing official business count, to be served consecutively, for a total aggregate prison

term of forty-eight months.

{¶12} Cunningham appeals from the August 1, 2025, judgment entry of the

Muskingum County Court of Common Pleas, and assigns the following as error:

{¶13} “I. CUNNINGHAM’S SENTENCE ON HIS TAMPERING WITH EVIDENCE

CONVICTION IS CONTRARY TO LAW BECAUSE THE TRIAL COURT MISAPPLIED

THE R.C. 2929.11 FACTORS.”

I.

{¶14} We review felony sentences using the standard of review set forth in R.C.

2953.08. State v. Marcum, 2016-Ohio-1002. R.C. 2953.08 provides we may either

increase, reduce, modify, or vacate a sentence and remand for sentencing where we clearly

and convincingly find either the record does not support the sentencing court’s findings

under R.C. 2929.13(B) or (D), R.C. 2929.14(B)(2)(e) or (C)(4), or R.C. 2929.20(I), or the

sentence is otherwise contrary to law. Id.

{¶15} Nothing in R.C. 2953.08 permits this Court to independently weigh the

evidence in the record and substitute our own judgment for that of the trial court to

determine a sentence that best reflects compliance with R.C. 2929.11 and R.C. 2929.12.

State v. Jones, 2020-Ohio-6729. Instead, we may only determine if the sentence is

contrary to law. A sentence is not clearly and convincingly contrary to law where the trial

court “considers the principles and purposes of R.C. 2929.11, as well as the factors listed

in R.C. 2929.12, properly imposes post-release control, and sentences the defendant within the permissible statutory range.” State v. Pettorini, 2021-Ohio-1512, ¶ 16 (5th

Dist.).

{¶16} When sentencing a defendant, the trial court must consider the purposes

and principles of felony sentencing set forth in R.C. 2929.11, and the seriousness and

recidivism factors in R.C. 2929.12. State v. Taylor, 2024-Ohio-238 (5th Dist.).

{¶17} “The overriding purposes of felony sentencing are to protect the public from

future crime by the offender and others, to punish the offender, and to promote the

effective rehabilitation of the offender using the minimum sanctions that the court

determines accomplish those purposes without imposing an unnecessary burden on state

or local government resources.” R.C. 2929.11(A). In order to achieve these purposes, “the

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

Related

State v. Marcum (Slip Opinion)
2016 Ohio 1002 (Ohio Supreme Court, 2016)
State v. Jones (Slip Opinion)
2020 Ohio 6729 (Ohio Supreme Court, 2020)
State v. Pettorini
2021 Ohio 1512 (Ohio Court of Appeals, 2021)
State v. Taylor
2024 Ohio 238 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Cunningham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cunningham-ohioctapp-2026.