State v. Hamilton

2023 Ohio 415
CourtOhio Court of Appeals
DecidedFebruary 13, 2023
Docket2022-L-074
StatusPublished

This text of 2023 Ohio 415 (State v. Hamilton) 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. Hamilton, 2023 Ohio 415 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Hamilton, 2023-Ohio-415.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY

STATE OF OHIO, CASE NO. 2022-L-074

Plaintiff-Appellee, Civil Appeal from the - vs - Court of Common Pleas

ANTON D. HAMILTON, JR., Trial Court No. 1999 CR 000231 Defendant-Appellant.

OPINION

Decided: February 13, 2023 Judgment: Affirmed

Charles E. Coulson, Lake County Prosecutor, and Teri R. Daniel, Assistant Prosecutor, Lake County Administration Building, 105 Main Street, P.O. Box 490, Painesville, OH 44077 (For Plaintiff-Appellee).

Anton D. Hamilton, Jr., pro se, PID# A379-712, Allen-Oakwood Correctional Institution, 2338 North West Street, P.O. Box 4501, Lima, OH 45802 (Defendant-Appellant).

MATT LYNCH, J.

{¶1} Defendant-appellant, Anton D. Hamilton, Jr., appeals the denial of his

Motion to Vacate a Void Judgment pursuant to State and Federal Law. For the following

reasons, we affirm the decision of the lower court.

{¶2} In 2004, following a jury trial in the Lake County Court of Common Pleas,

Hamilton was found guilty of Murder with a firearm specification. He is currently serving

an indefinite prison term of fifteen years to life with three additional years for the

specification. {¶3} On June 6, 2022, Hamilton filed a Motion to Vacate Void Judgment pursuant

to State and Federal Law.

{¶4} On July 15, 2022, the trial court denied the motion. The court aptly

summarized Hamilton’s arguments as follows:

In his motion, [Hamilton] denied that it was a postconviction petition but was instead a direct attack on a void judgment. He claims the trial court lacked subject matter jurisdiction because the indictment was filed the day after it was served on him. He also claims that the indictment lacked a “true bill” stamp on it, that there was no grand jury foreman signature on it, and there was no judge’s signature on it. He claims the only signature on it was from an assistant Lake County prosecutor. He further claims, without providing evidence, that the indictment was “more than likely a forged and fraudulent instrument” that was fabricated by the Lake County Prosecutor’s office. He also, implausibly, claims that the State of Ohio refused to accept and ratify the Fourteenth Amendment to the U.S. Constitution, thus depriving him of due process of law.

{¶5} The trial court considered Hamilton’s jurisdictional claims and concluded

that the Lake County Court of Common Pleas “had subject matter jurisdiction in the

complaint against Hamilton.” The court then construed Hamilton’s Motion as one for

postconviction relief: “although couched as a challenge to subject matter jurisdiction,

Hamilton’s motion to vacate merely raises a procedural issue and therefore shall be

treated as a postconviction petition.” Treated as such, the court found that it lacked

jurisdiction to consider the Motion inasmuch as Hamilton failed to satisfy the requirements

for filing successive petitions for postconviction relief. R.C. 2953.23(A). The court further

found Hamilton’s claim barred by res judicata as he “never raised the issue of subject

matter jurisdiction in his direct appeal or earlier postconviction petition.”

{¶6} On August 11, 2022, Hamilton filed a Notice of Appeal. On appeal, he

raises the following assignments of error:

Case No. 2022-L-074 [1.] The trial court exceeded it[s] authority, and Abused it[s] discretion, when it changed Appellant’s common law motion into a post-conviction petition, as a means to continue a void judgment, instead of ending it. In violation of state and federal due process.

[2.] The trial court exceeded it[s] authority by assuming personal jurisdiction, not properly obtained, but the trial judge has abused his discretion by claiming it was properly done.

[3.] The trial court exceeded it[s] authority and abused it[s] discretion when it used a void indictment to claim subject matter jurisdiction over the charges against appellant, resulting in a void judgment, but the trial judge has abused his discretion by saying it was properly filed, in violation of state and federal due process.

[4.] The trial court abused it[s] discretion when it refused to acknowledge public record evidence that challenges appellant’s standing as a U.S. citizen in Ohio, and the oath of office the trial court members took to support the state and federal constitutions for all Americans who enter these Ohio courthouses.

{¶7} The assignments of error will be considered in a consolidated manner.

{¶8} Hamilton asserts that the trial court erred by treating his common law Motion

as a postconviction petition so as to avoid confronting the issue of whether his conviction

is void. He maintains a motion to vacate a judgment as being void is distinct from a

postconviction petition that challenges the judgment as voidable.

{¶9} The distinction between a void judgment and a voidable judgment “turns on

whether the court [rendering judgment] had jurisdiction over the subject matter and the

person.” State v. Henderson, 161 Ohio St.3d 285, 2020-Ohio-4784, 162 N.E.3d 776, ¶

17. “A void judgment is rendered by a court without jurisdiction” whereas “[a] voidable

judgment is one pronounced by a court with jurisdiction.” Id.; State v. Perry, 10 Ohio

St.2d 175, 226 N.E.2d 104 (1967), paragraphs five and six of the syllabus.

{¶10} “Subject-matter jurisdiction refers to the constitutional or statutory power of

a court to adjudicate a particular class or type of case.” State v. Harper, 160 Ohio St.3d 3

Case No. 2022-L-074 480, 2020-Ohio-2913, 159 N.E.3d 248, ¶ 23. “[W]hen a specific action is within a court’s

subject-matter jurisdiction, any error in the exercise of that jurisdiction renders the court’s

judgment voidable, not void.” Id. at ¶ 26. The courts of common pleas are vested with

original jurisdiction of “all crimes and offenses, except in cases of minor offenses the

exclusive jurisdiction of which is vested in courts inferior to the court of common pleas.”

R.C. 2931.03; Article IV, Section 4(B), Ohio Constitution; Henderson at ¶ 35. Accordingly,

Hamilton’s Motion does not call into question the trial court’s subject-matter jurisdiction.

State v. Reed, 2d Dist. Clark No. 2021-CA-59, 2022-Ohio-3461, ¶ 19 (“Ohio appellate

courts have also concluded that the alleged failure to comply with the requirements of

Crim.R. 6(F) are unrelated to subject-matter jurisdiction and subject to res judicata”)

(cases cited); State v. Feathers, 11th Dist. Portage No. 2021-P-0004, 2021-Ohio-4137, ¶

14; State v. Smith, 9th Dist. Summit No. 29203, 2019-Ohio-1978, ¶ 5, fn. 1.

{¶11} “Personal jurisdiction refers to the court’s power to render a valid judgment

against a particular individual.” Henderson at ¶ 36. “In a criminal matter, the court

acquires jurisdiction over a person by lawfully issued process, followed by the arrest and

arraignment of the accused and his plea to the charge.” Id., citing Tari v. State, 117 Ohio

St. 481, 490, 159 N.E. 594 (1927). “A defendant also submits to the court’s jurisdiction if

he does not object to the court’s exercise of jurisdiction over him.” Id., citing Tari at 491.

Thus, “a challenge to personal jurisdiction or jurisdiction over the person is waivable by

the defendant’s voluntary submission at an initial appearance or by entering a plea of not

guilty.” State v. Mbodji, 129 Ohio St.3d 325, 2011-Ohio-2880, 951 N.E.2d 1025, ¶ 10.

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Related

State v. Mbodji
2011 Ohio 2880 (Ohio Supreme Court, 2011)
Tari v. State
159 N.E. 594 (Ohio Supreme Court, 1927)
State v. Smith
2019 Ohio 1978 (Ohio Court of Appeals, 2019)
State v. Harper (Slip Opinion)
2020 Ohio 2913 (Ohio Supreme Court, 2020)
State v. Henderson (Slip Opinion)
2020 Ohio 4784 (Ohio Supreme Court, 2020)
State v. Taylor
2021 Ohio 1670 (Ohio Court of Appeals, 2021)
State v. Feathers
2021 Ohio 4137 (Ohio Court of Appeals, 2021)
State v. Perry
226 N.E.2d 104 (Ohio Supreme Court, 1967)
Orr v. Mack
700 N.E.2d 590 (Ohio Supreme Court, 1998)
State v. Reed
2022 Ohio 3461 (Ohio Court of Appeals, 2022)
State v. Godfrey
2023 Ohio 20 (Ohio Court of Appeals, 2023)

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Bluebook (online)
2023 Ohio 415, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hamilton-ohioctapp-2023.