State v. Earl

2020 Ohio 1202
CourtOhio Court of Appeals
DecidedMarch 31, 2020
Docket18CA011303, 18CA011281
StatusPublished
Cited by1 cases

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Bluebook
State v. Earl, 2020 Ohio 1202 (Ohio Ct. App. 2020).

Opinion

[Cite as State v. Earl, 2020-Ohio-1202.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

STATE OF OHIO C.A. Nos. 18CA011303 18CA011281 Appellee

v. APPEAL FROM JUDGMENT ABDUL EARL ENTERED IN THE COURT OF COMMON PLEAS Appellant COUNTY OF LORAIN, OHIO CASE Nos. 15CR091866 16CR094318

DECISION AND JOURNAL ENTRY

Dated: March 31, 2020

TEODOSIO, Presiding Judge.

{¶1} Appellant, Abdul L. Earl, appeals from the judgment entries denying his two

motions to vacate void judgment in the Lorain County Court of Common Pleas. This Court

affirms.

I.

{¶2} Mr. Earl was sentenced in two separate cases and in two different trial courts. The

courts initially placed him on community control, but later sentenced him to prison after he violated

the terms and conditions of his community control. He never appealed any of the judgment entries

sentencing him to community control or prison. Mr. Earl eventually filed two motions to vacate

void judgment in each case almost a year after he was sentenced to prison, both of which were

denied. 2

{¶3} Mr. Earl now appeals from the judgment entries denying his two motions to vacate

void judgment and raises one assignment of error for this Court’s review. Although he filed

separate appeals in each case, this Court has consolidated both appeals, as they involve

substantially similar judgment entries and merit briefs, as well as the same assignment of error.

II.

ASSIGNMENT OF ERROR

APPELLANT WAS SENTENCED TO A []LUMP SENTENCE OF 3 YEARS COMMUNITY CONTROL. “LUMPING A SENTENCE IS A VIOLATION OF OHIO SENTENCING GUIDELINE[S].” * * *.

{¶4} In his sole assignment of error, Mr. Earl argues that both trial courts erred in

denying his motions to vacate void sentence because the courts originally imposed “lump”

sentences of three years community control in each case. We disagree.

{¶5} Although Mr. Earl has appealed from the denials of his motions to vacate void

judgment, he is essentially challenging his original sentences in each case. See State v. Williams,

5th Dist. Stark No. 2018CA00060, 2018-Ohio-3458, ¶ 17. “Most sentencing challenges must be

brought by a timely direct appeal.” State v. Ibn-Ford, 9th Dist. Summit No. 27380, 2015-Ohio-

753, ¶ 7, citing State v. Holdcroft, 137 Ohio St.3d 526, 2013-Ohio-5014, ¶ 8. See also State v.

Slaughter, 9th Dist. Lorain No. 18CA011293, 2019-Ohio-2154, ¶ 5. “The doctrine of res judicata

‘bars the assertion of claims against a valid, final judgment of conviction that have been raised or

could have been raised on appeal.’” State v. O’Neal, 9th Dist. Medina No. 15CA0052-M, 2015-

Ohio-5181, ¶ 5, quoting State v. Ketterer, 126 Ohio St.3d 448, 2010-Ohio-3831, ¶ 59. It “promotes

the principles of finality and judicial economy by preventing endless relitigation of an issue on

which a defendant has already received a full and fair opportunity to be heard.” State v. Saxon,

109 Ohio St.3d 176, 2006-Ohio-1245, ¶ 18. Res judicata applies to other aspects of the merits of 3

a conviction as well, including the determination of guilt and the lawful elements of the ensuing

sentence, but does not preclude review of a void sentence. State v. Fischer, 128 Ohio St.3d 92,

2010-Ohio-6238, paragraph three of the syllabus. In other words, unless Mr. Earl’s sentences are

void, his claim is barred by res judicata. See State v. Isa, 2d Dist. Champaign No. 2015-CA-44,

2016-Ohio-4980, ¶ 9; Ibn-Ford at ¶ 7.

{¶6} “A void sentence is one that a court imposes despite lacking subject-matter

jurisdiction or the authority to act.” State v. Payne, 114 Ohio St.3d 502, 2007-Ohio-4642, ¶ 27.

“‘Crimes are statutory, as are the penalties therefor, and the only sentence which a trial court may

impose is that provided for by statute.’” State v. Williams, 148 Ohio St.3d 403, 2016-Ohio-7658,

¶ 20, quoting Colegrove v. Burns, 175 Ohio St. 437, 438 (1964). “‘A court has no power to

substitute a different sentence for that provided for by statute or one that is either greater or lesser

than that provided for by law.’” Id. Thus, “[a]ny attempt by a court to disregard statutory

requirements when imposing a sentence renders the attempted sentence a nullity or void.” State

v. Beasley, 14 Ohio St.3d 74, 75 (1984).

{¶7} “Conversely, a voidable sentence is one that a court has jurisdiction to impose, but

was imposed irregularly or erroneously.” Payne at ¶ 27. Therefore, when a trial court has

jurisdiction but erroneously exercises its jurisdiction, the sentence is not void, and the sentence

can be set aside only if successfully challenged on direct appeal. Id. at ¶ 28. Sentencing errors are

generally not jurisdictional and do not render a judgment void. State v. Simpkins, 117 Ohio St.3d

420, 2008-Ohio-1197, ¶ 13. The Supreme Court of Ohio has, in fact, declined to find sentences

void based on the trial court’s failure to comply with certain sentencing statutes. See State v.

Holdcroft, 137 Ohio St.3d 526, 2013-Ohio-5014, ¶ 8 (recognizing challenges to a trial court’s (1)

compliance with the purposes and principles of sentencing, (2) determination of allied offenses, 4

and (3) consecutive sentencing must be brought on direct appeal); but see State v. Williams, 148

Ohio St.3d 403, 2016-Ohio-7658, ¶ 28 (separates sentences imposed for allied offenses of similar

import, even if imposed concurrently, are void).

{¶8} Mr. Earl claims that his sentences are void because each trial court imposed a

“lump” sentence of community control for multiple counts in each case. He relies on the Supreme

Court of Ohio’s decision in Saxon, which addressed and rejected use of the federal sentencing-

package doctrine by Ohio courts:

Instead of considering multiple offenses as a whole and imposing one, overarching sentence to encompass the entirety of the offenses as in the federal sentencing regime, a judge sentencing a defendant pursuant to Ohio law must consider each offense individually and impose a separate sentence for each offense. See R.C. 2929.11 through 2929.19. * * * Under the Ohio sentencing statutes, the judge lacks the authority to consider the offenses as a group and to impose only an omnibus sentence for the group of offenses.

Saxon at ¶ 9.

{¶9} This Court has consistently held that the Supreme Court of Ohio “‘has applied its

void-sentence analysis in limited circumstances’” and we “‘will not extend its reach without clear

direction from the Supreme Court.’” See, e.g., Slaughter, 2019-Ohio-2154, at ¶ 9, quoting State

v. Culgan, 9th Dist. Medina No. 09CA0060-M, 2010-Ohio-2992, ¶ 20. Notably, the high court

has identified several specific areas where it held that a sentence was void: “when the trial court

fails to impose a statutorily mandated term of post[-]release control,” “when it fails to include a

mandatory driver’s license suspension in the offender’s sentence[,]” and “when it fails to include

a mandatory fine in the sentence[.]” Williams, 2016-Ohio-7658, at ¶ 21. The Williams Court

further determined that separates sentences imposed for allied offenses of similar import, even if

imposed concurrently, are void. Id. at ¶ 28. Mr. Earl has not alleged that any of these specific

errors occurred in his cases. Although the Saxon Court determined sentencing courts lack the 5

authority to consider multiple offenses as a group and err in imposing a single sentence for those

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2020 Ohio 1202, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-earl-ohioctapp-2020.