State v. Harvey

2023 Ohio 1614
CourtOhio Court of Appeals
DecidedMay 15, 2023
Docket1-22-43
StatusPublished

This text of 2023 Ohio 1614 (State v. Harvey) 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. Harvey, 2023 Ohio 1614 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Harvey, 2023-Ohio-1614.]

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

STATE OF OHIO,

PLAINTIFF-APPELLEE, CASE NO. 1-22-43

v.

JAQUAVEIUS E. HARVEY, OPINION DEFENDANT-APPELLEE,

[CASTLE BAIL BONDS - APPELLANT].

Appeal from Allen County Common Pleas Court Trial Court No. CR 2020 0383

Judgment Affirmed

Date of Decision: May 15, 2023

APPEARANCES:

April F. Campbell for Appellant

John R. Willamowski, Jr. for Appellee, State of Ohio Case No. 1-22-43

EPLEY, J.

{¶1} Appellant, Castle Bail Bonds, surety for Jaquaveius E. Harvey, appeals

from the judgment of the Allen County Court of Common Pleas after the court

entered a $250,000 forfeiture judgment against it because Harvey failed to appear

for his felony case. For the reasons that follow, the judgment of the court will be

affirmed.

I. Facts and Procedural History

{¶2} In October 2020, Harvey was charged with multiple serious drug crimes

including trafficking in heroin and engaging in a pattern of corrupt activity. He

entered a plea of not guilty and bond was set at $250,000. A few months later, Castle

Bail Bonds (“Castle”) became surety for Harvey, posting bond on his behalf. The

case proceeded with many hearings and motions, until Harvey failed to appear for

his final pre-trial hearing on September 17, 2021. A bench warrant was issued on

September 20, 2021.

{¶3} On January 10, 2022, after months of Harvey being unaccounted for,

the State filed a motion to forfeit bond. On January 27, Castle filed a motion to be

released from the bond, citing “new” charges (the charges were filed in April of

2021, but Castle claimed to have been unaware of them until recently) that

amounted to a violation of the bond agreement. On February 15, 2022, the court

heard the State’s motion and ordered the entire bond forfeited. It further denied

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Castle’s request to be removed as surety and ordered Castle to show cause on or

before April 12, 2022, why judgment should not be entered against it.

{¶4} At the April 12 show cause hearing, the court heard testimony from

Dana Barnhart, an agent and recovery officer at Castle. She testified that she had

spent “countless hours between Lima, Ohio and Fort Wayne, Indiana, trying to

recover [Harvey].” Hearing Tr. at 4-5. She also explained that she had hired outside

recover agents to help in the search. Despite the time and effort, agents had been

unsuccessful in the quest to locate Harvey. Barnhart also testified that she had tried

to get the US Marshalls to help in the search, but they allegedly told her that they

needed an invite from the Allen County Prosecutor’s Office to assist. She did admit,

however, that she had not reached out to the West Ohio Crime Task Force or the

prosecutor’s office for assistance.

{¶5} At the close of the hearing, the court granted a 45-day extension, and

suggested reaching out to the assistant prosecutor assigned to drug cases because

she would have useful contacts with law enforcement who would also be interested

in getting Harvey off the streets. The trial court also noted that it had expanded the

warrant pick-up radius to “nationwide.”

{¶6} A second show cause hearing took place on May 27, 2022. During that

proceeding, the court heard from Barnhart again, and from Matthew King, the

director of recovery for Dawgtown, Inc., another bail bonds enterprise looking for

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Harvey on another case. King testified that while no one had been able to capture

Harvey, he had spent more than $18,000 looking for him. He also told the court that

he thinks he knows where Harvey is, and on multiple occasions, has been just

minutes too late in recovery efforts. He stated, “I am very confident * * * that Mr.

Harvey is still here in Lima and is bouncing around from several different

addresses.” Hearing Tr. at 18.

{¶7} Barnhart also testified on behalf of Castle. She complained that the

prosecutor’s office had been too busy to help, but the Marshalls were actively

looking for Harvey. She stated that she has physically seen him but has been unable

to capture him to this point.

{¶8} At the close of testimony, the court granted one last 45-day extension

to Castle but made it clear that this was the last shot – they had until July 11 at 7:30

to recover Harvey. There would be no more extensions. When Harvey’s

whereabouts were still unknown on July 11, the court held that Castle had not shown

good cause as to why judgment should not be entered, and ordered the bond forfeited

in the amount of $250,000.

{¶9} Castle has filed a timely appeal.

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II. Bond Forfeiture

{¶10} In its lone assignment of error, Castle argues that the trial court abused

its discretion when it was ordered to pay the $250,000 bond forfeiture order. We

disagree.

{¶11} “Bail bonds are contracts between the surety and the state.” State v.

Lott, 2014-Ohio-3404, 17 N.E.3d 1167, ¶ 8 (1st Dist.). The surety agrees to ensure

that the defendant appears in court and the state agrees to release the defendant into

the custody of the surety. Id. If a defendant fails to appear for court, there is a breach

of the condition of bond and a trial court may declare a forfeiture of it unless the

surety can be exonerated as provided by law. State v. Guzman, 2020-Ohio-539, 152

N.E.3d 412, ¶ 9 (3d Dist.); State v. Hughes, 27 Ohio St.3d 19, 20, 501 N.E.2d 622

(1986). A final judgment of forfeiture in the case of a recognizance surety bond

consists of two steps: (1) adjudication of bail forfeiture pursuant to R.C. 2937.35,

and (2) a forfeiture show cause hearing under R.C. 2937.36. Id.

{¶12} According to R.C. 2937.36, a trial court must notify (“by ordinary mail

at the address shown by them in their affidavits of qualification or on the record of

the case”) the defendant and the defendant’s surety of the defendant’s failure to

appear and the court’s declaration of the forfeiture within 15 days of the order. R.C.

2937.36(C). After recognizance is declared forfeited, the surety and defendant must

show cause (between 45 and 60 days of the date of the mailing notice) why judgment

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should not be entered against them for the penalty stated in the recognizance. R.C.

2937.36(C). “When good cause is not shown, the trial court must enter judgment

against them in an amount which does not exceed the face of the bond.” Id. A surety

can be exonerated if good cause “by production of the body of the accused or

otherwise” is shown. R.C. 2937.36(C).

{¶13} An appeals court reviews a bond forfeiture decision for an abuse of

discretion. Guzman at ¶ 7. See also State v. Thornton, 2d Dist. Montgomery No.

20963, 2006-Ohio-786, ¶ 13. To constitute an abuse of discretion, a trial court’s

action must be arbitrary, unreasonable, or unconscionable. Ojalvo v. Bd. of Trustees

of Ohio State Univ., 12 Ohio St.3d 230, 232, 466 N.E.2d 875 (1984).

{¶14} Castle’s main argument is that Harvey made his capture impossible

during the timeframe given by the trial court. It argues that Harvey was being

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Related

State v. Lott
2014 Ohio 3404 (Ohio Court of Appeals, 2014)
State v. Thornton, Unpublished Decision (2-17-2006)
2006 Ohio 786 (Ohio Court of Appeals, 2006)
State v. Scherer
671 N.E.2d 545 (Ohio Court of Appeals, 1995)
State v. Guzman
2020 Ohio 539 (Ohio Court of Appeals, 2020)
State v. Jackson
2021 Ohio 1646 (Ohio Court of Appeals, 2021)
Ojalvo v. Board of Trustees
466 N.E.2d 875 (Ohio Supreme Court, 1984)
State v. Hughes
501 N.E.2d 622 (Ohio Supreme Court, 1986)

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Bluebook (online)
2023 Ohio 1614, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-harvey-ohioctapp-2023.