State v. Fleming

2023 Ohio 849
CourtOhio Court of Appeals
DecidedMarch 17, 2023
DocketC-220275
StatusPublished
Cited by1 cases

This text of 2023 Ohio 849 (State v. Fleming) 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. Fleming, 2023 Ohio 849 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Fleming, 2023-Ohio-849.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-220275 TRIAL NO. 22CRB-7556 Plaintiff-Appellee, :

vs. : O P I N I O N. ARIUS FLEMING, :

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Reversed and Appellant Discharged

Date of Judgment Entry on Appeal: March 17, 2023

Emily Smart Woerner, City Solicitor, William T. Horsley, Chief Prosecuting Attorney, and Rebecca Barnett, Assistant Prosecuting Attorney, for Plaintiff-Appellee,

Raymond T. Faller, Hamilton County Public Defender, and Lora Peters, Assistant Public Defender, for Defendant-Appellant. OHIO FIRST DISTRICT COURT OF APPEALS

KINSLEY, Judge.

{¶1} Defendant-appellant Arius Fleming appeals his conviction for violating

a protection order. Because the state did not present sufficient evidence that Fleming

was served with, shown, or informed by a legal authority about the final protection

order, we reverse Fleming’s conviction and discharge Fleming from further

prosecution.

I. Facts and Procedure

{¶2} On April 17, 2020, J.K., Fleming’s mother, filed a petition against him

for a civil stalking protection order under R.C. 2903.214. In accordance with R.C.

2903.214(D)(1), the trial court granted an ex parte order on the same day. On April

17, 2020, the ex parte order was personally served on Fleming by Hamilton County

Deputy Sheriff Tony Pritchett. The ex parte order remained effective until April 17,

2021.

{¶3} On May 6, 2020, the magistrate issued an interim protection order,

which was to expire on April 16, 2025. The magistrate’s interim order was journalized

on May 7, 2020. That order included the date of the upcoming final-order hearing and

also requested that the clerk serve the parties by mail. Other than the order itself,

there was no evidence at trial to indicate that the clerk actually mailed the order to

Fleming or to which address the order might have been sent.

{¶4} A full hearing on the final order was conducted on May 28, 2020.

Fleming did not appear. Following the hearing, the trial court issued a final order

adopting the civil protection order. The final order instructed the clerk to send a copy

to all parties who had appeared in the action via mail. There is no evidence that the

final civil protection order was ever personally served on Fleming.

2 OHIO FIRST DISTRICT COURT OF APPEALS

{¶5} Nearly two years later, on May 7, 2022, Fleming was charged with

violating the protection order. The trial court held a bench trial in June 2022. Deputy

Pritchett explained the procedure that he uses when serving a protection order and

testified that he personally served Fleming with the ex parte order, which expired on

April 17, 2021.

{¶6} J.K. testified that she told Fleming about the protection order “a lot of

times” and did so prior to the May 2022 incident. Her testimony did not indicate

which version of the protection order formed the basis of her conversations: the ex

parte order, the magistrate’s interim order, or the final order. She further testified

that, on the date of the incident, Fleming came to her home and got into a

“confrontation” with her other son, so she told Fleming to leave.

{¶7} Officer Morehead testified that he responded to J.K.’s home for an

allegation that Fleming was there with a knife and was behaving erratically. J.K. “came

running out of her apartment” upon Officer Morehead’s arrival, and Officer Morehead

took Fleming into custody.

{¶8} The trial court found Fleming guilty of violating the protection order.

Fleming was sentenced to 180 days in jail with 24 days credited, fined $250, and

encouraged to participate in mental-health and/or substance-abuse treatment. This

appeal followed.

II. Law and Analysis

A. There is no proof of service of the final order on Fleming.

{¶9} Fleming argues in his first assignment of error that the state failed to

prove beyond a reasonable doubt that Fleming was served with a final copy of the

protection order. He contends that his conviction for violating the protection order

3 OHIO FIRST DISTRICT COURT OF APPEALS

was based on insufficient evidence, contrary to the manifest weight of the evidence,

and contrary to law.

1. The evidence of service was insufficient.

{¶10} The test for determining the sufficiency of the evidence is whether “after

viewing the probative evidence and inferences reasonably drawn therefrom in the light

most favorable to the prosecution, any rational trier of fact could have found all the

essential elements of the offense beyond a reasonable doubt.” State v. MacDonald,

1st Dist. Hamilton No. C-180310, 2019-Ohio-3595, ¶ 12, quoting State v. Martin, 20

Ohio App.3d 172, 485 N.E.2d 717 (1st Dist.1983). It is a question of law for the court

to determine, and this court is not to weigh the evidence unless, after viewing the

evidence, it weighs heavily against conviction. Id. at ¶ 12.

{¶11} Fleming was charged with recklessly violating a protection order under

R.C. 2919.27. More specifically, the complaint contends that Fleming recklessly

violated the terms of a civil protection order issued by the trial court on April 29, 2020,

pursuant to R.C. 2919.26. However, no protection order was issued by the court on

April 29, 2020. The only protection orders issued against Fleming were (1) the ex

parte order issued on April 17, 2020, (2) the interim order issued on May 6, 2020, and

(3) the final order issued on May 28, 2020.

{¶12} In State v. Smith, the Ohio Supreme Court held that service of the civil

protection order on the defendant is an element the state must prove beyond a

reasonable doubt in any prosecution for violating a civil protection order under R.C.

2919.27(A). State v. Smith, 136 Ohio St.3d 1, 2013-Ohio-1698, 989 N.E.2d 972, ¶ 28.

The court also held that service in the context of civil protection orders has the same

meaning as it does under the Ohio Rules of Civil Procedure. Id. at ¶ 21.

4 OHIO FIRST DISTRICT COURT OF APPEALS

{¶13} Civ.R. 4.1 provides that service may be made by (1) clerk via United

States certified or express mail, (2) personal service, or (3) residence service. Proof of

service is either a return receipt for certified mail, a signed receipt for commercial

service by the clerk, or an entry of process on the docket for personal or residential

service. Id.

{¶14} The state did present evidence that Fleming was personally served with

the ex parte protection order—which expired more than a year prior to the alleged

violation. The state, however, presented no evidence that Fleming was served with

either the interim or the final protection orders in accordance with Civ.R. 4.1. While

the interim and final orders contained instructions to the clerk to serve them by mail,

the state presented no evidence of either a return receipt for certified mail or an entry

of process on the docket in accordance with Civ.R. 4.1. Thus, there was insufficient

evidence that the final order of protection was served on Fleming.

{¶15} But this does not end the inquiry. R.C. 2919.27(D), which was enacted

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Bluebook (online)
2023 Ohio 849, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-fleming-ohioctapp-2023.