State v. Cutright

2025 Ohio 2507
CourtOhio Court of Appeals
DecidedJuly 16, 2025
Docket24CA000037 & 24CA000038
StatusPublished

This text of 2025 Ohio 2507 (State v. Cutright) 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. Cutright, 2025 Ohio 2507 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Cutright, 2025-Ohio-2507.]

COURT OF APPEALS GUERNSEY COUNTY, OHIO FIFTH APPELLATE DISTRICT

JUDGES: STATE OF OHIO : Hon. Craig R. Baldwin, P.J. : Hon. Robert G. Montgomery, J. Plaintiff-Appellee : Hon. Kevin W. Popham, J. : -vs- : : Case Nos. 24CA000037 & RANDY D. CUTRIGHT, JR. 24CA000038 : Defendant-Appellant : : OPINION

CHARACTER OF PROCEEDING: Appeal from the Guernsey County Court of Common Pleas, Case Nos. 24CR000099 & 24CR000164

JUDGMENT: Affirmed

DATE OF JUDGMENT ENTRY: July 16, 2025

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

MARK A. PERLAKY MICHAEL GROH Assistant Guernsey County Prosecutor 1938 E. Wheeling Avenue 627 Wheeling Avenue Cambridge, OH 43725 Cambridge, OH 43725 Popham, J.,

{¶1} Defendant-Appellant Randy Cutright, Jr. (“Cutright”) appeals his sentence

after a negotiated guilty plea in the Guernsey County Court of Common Pleas. For the

reasons below, we affirm.

Facts and Procedural History

{¶2} On May 26, 2024, while on post-release control for a 2023 felony domestic

violence conviction, Cutright went to a bar. Sent. T. at 27. Upon leaving the bar, he went

to the home of the victim, with whom he had a past relationship. The victim was asleep

when Cutright picked the lock and entered her home. Id. As the victim attempted to hold

the bedroom door shut, Cutright broke it off its hinges, and the door struck the victim in

the face. Id. at 28. At some point during the struggle, Cutright hit the victim in her face

with the palm of his hand. Id. Cutright had three prior domestic violence convictions.

{¶3} On June 11, 2024, Cutright was indicted in Guernsey County Court of

Common Pleas, Case No. 24CR000099, for one count of domestic violence, a third-

degree felony in violation of R.C. 2919.25(A)/(D)(4), and one count of burglary, a second-

degree felony in violation of R.C. 2911.12(A)(2)/(D). While in the Guernsey County Jail

on these charges, Cutright broke a television set. He was subsequently indicted in Case

No. 24CR000164 for one count of vandalism, a fifth-degree felony in violation of R.C.

2909.05(B)(1)(b)/(E).

{¶4} In exchange for a guilty plea, the State amended the burglary charge from

a second-degree felony to attempted burglary, a third-degree felony. On September 25,

2024, a Crim.R. 11(C) and (F) negotiated plea form, signed by Cutright, his attorney, and

the assistant prosecuting attorney, was filed. (Docket Entry No. 12). That same day, Cutright entered guilty pleas to the domestic violence, attempted burglary, and vandalism

charges. The trial court ordered a presentence investigation report, and sentencing was

deferred.

{¶5} On November 21, 2024, the trial court reviewed the presentence

investigation report and heard statements from Cutright, his counsel, and the State. The

court heard that Cutright committed these offenses while on post-release control for a

2023 felony domestic violence conviction. Sent. T. at 12. The court also considered

Cutright’s extensive criminal history, which began when he was a juvenile.

{¶6} The trial court sentenced Cutright to 24 months in prison for the domestic

violence count, 24 months in prison for the attempted burglary count, and 9 months in

prison for the vandalism count – all to be served consecutively. The trial court also

sentenced Cutright to 1 year in prison for the post-release control violation, to be served

prior to and consecutive to the other imposed sentences. The aggregate prison sentence

was 57 months for the convictions in Case Nos. 24CR000099 and 24CR000164, plus the

one year for the termination of post-release control. Sent. T. at 31. The court issued a

nunc pro tunc sentencing entry on November 27, 2024, to correct clerical references to

post-release control.

Assignment of Error

{¶7} Cutright raises one assignment of error for our consideration,

{¶8} “I. THE TRIAL COURT COMMITTED PLAIN ERROR BY FAILING TO

MERGE THE COUNT OF DOMESTIC VIOLENCE AND THE COUNT OF ATTEMPTED

BURGLARY THAT WERE RELATED TO THE SAME INCIDENT.” Law and Analysis

{¶9} Cutright argues the trial court erred in not merging the domestic violence

with the burglary conviction pursuant to R.C. 2941.25. He concedes that he did not argue

for merging the offenses at the time of sentencing.

{¶10} R.C. 2941.25, Multiple counts states:

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.

(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.

{¶11} In State v. Rogers, 2015-Ohio-2459, the Supreme Court of Ohio considered

whether multiple convictions resulting from a guilty plea should have been merged at

sentencing under R.C. 2941.25. Rogers raised this issue for the first time on appeal. Id.

at ¶ 11.

{¶12} Upon review of the certified conflict case, the Rogers Court clarified the

difference between waiver and forfeiture concerning allied offenses. Id. at ¶¶ 19–21. It

rejected the argument that guilty pleas to potentially allied offenses constitute a waiver of

protection under R.C. 2941.25. Instead, the Court held that an accused’s failure to seek merger in the trial court constitutes a forfeiture of the claim for appellate review. Id. at ¶

21. The Court explained:

[F]orfeiture is the failure to timely assert a right or object to an error,

and … an appellate court will not consider any error which counsel for a

party complaining of the trial court’s judgment could have called but did not

call to the trial court’s attention at a time when such error could have been

avoided or corrected by the trial court.

Id.

{¶13} However, an accused may raise a forfeited claim on appeal through

Crim.R. 52(B), which states that “plain errors or defects affecting substantial rights

may be noticed although they were not brought to the attention of the court.” In

clarifying the Crim.R. 52(B) distinction between plain and forfeited error, the

Rogers Court held:

An accused’s failure to raise the issue of allied offenses of similar

import in the trial court forfeits all but plain error, and a forfeited error is not

reversible unless it affected the outcome of the proceeding and reversal is

necessary to correct a manifest miscarriage of justice.

Rogers, ¶ 3. See also State v. Wolfe, 2022-Ohio-117, ¶¶ 26–28.

{¶14} Where evidence supporting one criminal count is separate and

distinct from the evidence supporting another count, a defendant has the burden

to demonstrate to a reasonable probability that the convictions are for allied

offenses of similar import committed with the same conduct and without a separate animus. Wolfe, ¶¶ 35, 38. So too here, it is Cutright’s burden to demonstrate that

the convictions were for allied offenses of similar import.

{¶15} However, even if plain error is shown, the appellate court is not obligated to

correct it. The Rogers Court emphasized:

We have admonished courts to notice plain error “with the utmost

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

Related

United States v. Broce
488 U.S. 563 (Supreme Court, 1989)
State v. Carr
2016 Ohio 9 (Ohio Court of Appeals, 2016)
State v. Starr
2016 Ohio 8179 (Ohio Court of Appeals, 2016)
State v. Wolfe
2022 Ohio 117 (Ohio Court of Appeals, 2022)
State v. Barnes
759 N.E.2d 1240 (Ohio Supreme Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2507, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cutright-ohioctapp-2025.