State v. Dixon

2025 Ohio 326
CourtOhio Court of Appeals
DecidedFebruary 3, 2025
Docket8-24-05
StatusPublished
Cited by3 cases

This text of 2025 Ohio 326 (State v. Dixon) 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. Dixon, 2025 Ohio 326 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Dixon, 2025-Ohio-326.]

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

STATE OF OHIO, CASE NO. 8-24-05 PLAINTIFF-APPELLANT,

v.

ERIC DIXON, OPINION

DEFENDANT-APPELLEE.

Appeal from Logan County Common Pleas Court Trial Court No. CR 21 10 0280

Judgment Affirmed

Date of Decision: February 3, 2025

APPEARANCES:

Erin G. Rosen for Appellant Case No. 8-24-05

WILLAMOWSKI, J.

{¶1} The State of Ohio appeals the judgment of the Logan County Court of

Common Pleas, arguing that the trial court erred by dismissing the indictment

against defendant-appellee Eric Dixon (“Dixon”). For the reasons set forth below,

the judgment of the trial court is affirmed.

Facts and Procedural History

{¶2} On November 9, 2021, Dixon was indicted on two counts of passing

bad checks in violation of R.C. 2913.11(B), first-degree misdemeanors. The State

alleged that Dixon had issued two bad checks to Ohio Ready Mix Concrete

(“ORMC”). Subsequently, the State and Dixon reached an agreement to resolve

this case. Under this agreement, the State offered to dismiss the charges if Dixon

paid restitution in the amount of roughly $2,040.00 to ORMC.1

{¶3} Defense counsel received an email from the State that directed him to

mail a check to their victim advocate at the prosecutor’s office. On June 27, 2023,

defense counsel followed the instructions from the email and mailed a cashier’s

check from Dixon that was in the amount of $2,040.00. However, this cashier’s

check was intercepted by a third party; the payee’s name was altered from “Ohio

Ready Mix” to “Alidoumbia”; and the check was negotiated.

1 In the judgment entry of dismissal, the trial court stated that the amount Dixon was to pay to ORMC in restitution was $2,005.18. However, Dixon made out a check to ORMC in the amount of $2,040.00.

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{¶4} After discussing this situation at a status conference on January 5, 2024,

the trial court noted that, “[t]here’s been no, in th[is] discussion, indication to the

Court that Mr. Dixon was in any way involved” with the interception or negotiation

of the cashier’s check. (Jan. 5 Tr. 4). The trial court then stated the theft of these

funds was “criminal behavior on the part of another person that has intervened and

super[s]eded Mr. Dixon’s * * * getting restitution to the victim.” (Id. at 4). The

trial court then indicated that a dismissal of the charges appeared to be the proper

course of action but scheduled another hearing to address this matter further.

{¶5} At a hearing on January 31, 2024, defense counsel indicated that the

bank was not going to refund the money that was taken by the third party. The State

argued that the charges against Dixon should not be dismissed because “the

agreement had not been completed in that [ORMC] ha[d] not yet been made whole

* * *.” (Jan. 31 Tr. 7). Defense counsel argued that “the defendant accepted the

plea offer and provided valuable consideration, which consummated the deal * * *.”

(Id. at 10).

{¶6} On February 1, 2024, the trial court issued a judgment entry that

dismissed the charges against Dixon. This entry began by noting that the record

contained no evidence that Dixon “had anything to do with the interception, altering,

and negotiation of the check.” (Doc. 45). The trial court then reasoned that

agreements between the State and a defendant are generally subject to the principles

of contract law. Pursuant to the mailbox rule, the trial court found that Dixon

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accepted the State’s offer by mailing the cashier’s check as instructed to

prosecutor’s office. After finding that Dixon had performed under the contract, the

trial court concluded that the State was bound by its agreement with Dixon.

{¶7} The State of Ohio filed its notice of appeal on February 6, 2024. On

appeal, the appellant raises the following two assignments of error:

First Assignment of Error

Whether the trial court erred in dismissing, sua sponte, a criminal indictment alleging fraud by Passing Bad Checks, based upon misapplication of the ‘mailbox rule.’

Second Assignment of Error

Whether the trial court abused its discretion in dismissing the indictment under presumed authority of Crim.R. 48(B).

{¶8} The State of Ohio argues that the trial court did not properly apply the

mailbox rule in determining that the State was bound by the agreement to dismiss

the charges in this case.

Legal Standard

{¶9} The State can enter into an agreement with a defendant for the

“resolution of criminal proceedings.” State v. Sibley, 2011-Ohio-4861, ¶ 19 (6th

Dist.). Such an agreement “is a contract between the prosecution and a criminal

defendant * * *.” State v. Grier, 2011-Ohio-902, ¶ 18 (3d Dist.). For this reason,

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the “principles of contract law are generally applicable to the interpretation and

enforcement of plea agreements.” State v. Bush, 2023-Ohio-4473, ¶ 54 (3d Dist.).

A contract consists of an offer, an acceptance, and consideration. * * * Under Ohio law, consideration consists of either a benefit to the promisor or a detriment to the promisee. To constitute consideration, the benefit or detriment must be ‘bargained for.’ Something is bargained for if it is sought by the promisor in exchange for his promise and is given by the promisee in exchange for that promise.

State v. Moore, 2024-Ohio-1354, ¶ 17 (9th Dist.), quoting Carlisle v. T & R

Excavating, Inc., 123 Ohio App.3d 277, 283 (9th Dist. 1997). “Since a plea

agreement is a contract, to be construed strictly against the state, the prosecutor is

required to fulfill any promise or agreement of the state.”2 State v. Santiago, 2023-

Ohio-561, ¶ 15 (3d Dist.), quoting State v. Zamora, 2007-Ohio-6973, ¶ 12 (3d Dist.).

Standard of Review

{¶10} The existence or interpretation of a contract present questions of law

that appellate courts review de novo. GigSmart, Inc. v. AxleHire, Inc., 2023-Ohio-

3807, ¶ 31 (1st Dist.); Chuma v. Patterson, 2023-Ohio-1128, ¶ 37 (4th Dist.). “De

novo review is independent” and does not give “deference to the lower court’s

decision.” State v. Tasciuc, 2024-Ohio-5556, ¶ 17 (3d Dist.), quoting State v.

Hudson, 2013-Ohio-647, ¶ 27 (3d Dist.). However, on appeal, “great deference is

2 We note that this arrangement is somewhat different from the type of agreement that is generally used to resolve a criminal case because the State did not ultimately seek a plea from Dixon in this case. Nonetheless, Dixon and the State entered into this agreement to bring about the resolution of a criminal case. As such, this arrangement will be held to the general legal standards that govern the typical plea agreement. See State v. Lacy, 1984 WL 4049, *2 (2d Dist. Oct. 5, 1984).

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given to the trial court’s factual findings supporting its legal conclusions.” Chuma

at ¶ 37. As the finder of fact, the trial court has “the duty * * * to determine whether

there has been compliance with a plea agreement.” State v. Emch, 2023-Ohio-3553,

¶ 22 (5th Dist.), citing State v. Curry, 49 Ohio App.2d 180, 183 (9th Dist. 1976).

See also State v. Namack, 2002-Ohio-5187, ¶ 26 (7th Dist.).

Legal Analysis

{¶11} Both parties agree that the State offered to dismiss the charges against

Dixon if he paid restitution in the amount of roughly $2,040.00. Pursuant to the

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Bluebook (online)
2025 Ohio 326, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-dixon-ohioctapp-2025.