State v. Hoffer

2026 Ohio 235
CourtOhio Court of Appeals
DecidedJanuary 23, 2026
DocketCT2025-0076
StatusPublished

This text of 2026 Ohio 235 (State v. Hoffer) 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. Hoffer, 2026 Ohio 235 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Hoffer, 2026-Ohio-235.]

COURT OF APPEALS MUSKINGUM COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO, Case No. CT2025-0076

Plaintiff - Appellee Opinion & Judgment Entry

-vs- Appeal from the Court of Common Pleas of Muskingum County, JOHN T. R. HOFFER, Case No. CR2025-0123

Defendant - Appellant Judgment: Affirmed

Date of Judgment: January 23, 2026

BEFORE: Craig R. Baldwin; Kevin W. Popham; David M. Gormley, Judges

APPEARANCES: Joseph A. Palmer, Muskingum County Prosecuting Attorney’s Office, Zanesville, Ohio, for Plaintiff-Appellee; April F. Campbell, Dublin, Ohio, for Defendant- Appellant.

Gormley, J.

{¶1} Appellant John Hoffer challenges his convictions on charges of felonious

assault and discharging a firearm on or near prohibited premises. According to Hoffer,

the crimes were allied offenses that should have been merged before he was sentenced.

Because we agree with the trial court’s conclusion about the merger issue, we affirm

Hoffer’s sentence on both charges.

The Key Facts

{¶2} In December 2024, a woman was allegedly sexually assaulted at a home

on Swingle Street in Zanesville. A carload of angry people then drove to that home, and

while they were outside it, someone came out of the home with a gun. That prompted the group in the car to leave the residence, and they then drove to a nearby apartment

complex where they began to devise a plan to return to the residence and confront the

individual whom they believed had sexually assaulted the woman. At this point, Hoffer

joined the group.

{¶3} Now themselves armed with firearms, Hoffer and the others in the car began

driving back toward the home on Swingle Street. Before they reached that destination,

though, they saw someone walking on Greenwood Avenue. Believing that that person

had been involved in the suspected sexual assault, a passenger in the vehicle tried to

shoot him with a shotgun. When that passenger was unable to fire the gun, Hoffer

grabbed it and fired two shots at the pedestrian, who was seriously injured by the gunfire.

{¶4} Hoffer and others were indicted on multiple charges stemming from the

incident. Hoffer agreed to plead guilty to the charges of felonious assault (along with an

accompanying firearm specification alleging that the crime had been — in the words of

R.C. 2941.146(A) — “committed by discharging a firearm from a motor vehicle”),

discharging a firearm on or near prohibited premises, and having a weapon while under

a disability. The plea agreement did not include any recommendation on the sentence.

{¶5} At the sentencing hearing, the parties initially expressed differing views

about whether the felonious-assault and discharging-a-firearm charges should be

merged. The State argued that the felonious-assault charge addressed Hoffer’s shooting

of the victim, while the discharging-a-firearm charge addressed his act of shooting over a

roadway. Hoffer’s counsel ultimately agreed that the charges “don’t merge under a strict

analysis of the rough factors.” The trial court then found that the two charges did not

merge, and Hoffer was convicted and sentenced on both of them. {¶6} Hoffer now appeals, arguing in his sole assignment of error that the trial

court erred by failing to merge the two charges.

The Trial Court Correctly Declined to Merge Charges of Felonious Assault and Discharging a Firearm on or Near Prohibited Premises

{¶7} An appellate court reviews de novo a trial court’s ruling on whether offenses

merge under R.C. 2941.25. State v. Williams, 2012-Ohio-5699, ¶ 28. That statute

provides that “[w]here the same conduct by defendant can be construed to constitute two

or more allied offenses of similar import, the indictment . . . may contain counts for all

such offenses, but the defendant may be convicted of only one.” R.C. 2941.25(A). “At

the heart of R.C. 2941.25 is the judicial doctrine of merger” which “‘prohibits multiple

punishments for the same offense.’” Williams at ¶ 13, quoting State v. Underwood, 2010-

Ohio-1, ¶ 23.

{¶8} In determining whether two or more crimes are “allied offenses of similar

import,” courts must look at the three separate factors of conduct, animus, and import.

State v. Ruff, 2015-Ohio-995, paragraph one of the syllabus. By pleading guilty to

felonious assault, Hoffer admitted that he had knowingly caused (or attempted to cause)

physical harm to another using a deadly weapon. R.C. 2903.11(A)(2). And in pleading

guilty to discharging a firearm on or near prohibited premises, Hoffer admitted to

discharging a firearm on or over a public road or highway and, as a result of that

discharge, causing serious physical harm to a person. R.C. 2923.162(A)(3) and (C)(4).

That latter crime does not require the State to prove any particular guilty mindset on the

part of a defendant, for as we have explained, R.C. 2923.162 “‘is a statute intended to

benefit the public good and thus imposes strict liability.’” State v. Thorpe, 2024-Ohio-

1957, ¶ 21 (5th Dist.), quoting State v. James, 2015-Ohio-4987, ¶ 33 (8th Dist.). {¶9} Hoffer contends that the same conduct — firing a gun from a vehicle and

causing physical harm to a victim — underlies both the felonious-assault and discharging-

a-firearm charges. But two offenses are of dissimilar import “‘when the defendant’s

conduct constitutes offenses involving separate victims or if the harm that results from

each offense is separate and identifiable.’” Thorpe at ¶ 18, quoting Ruff at paragraph two

of the syllabus. “[W]hen the defendant’s conduct put more than one individual at risk, that

conduct could support multiple convictions because the offenses were of dissimilar

import.” Ruff at ¶ 23.

{¶10} Ohio courts, including ours, have repeatedly held that the crimes of

felonious assault and discharging a firearm on or near prohibited premises do not merge

because an individual is the victim of the former, while the public is the victim of the latter.

See, e.g., State v. Henry, 2025-Ohio-774, ¶ 19–20 (6th Dist.) (“The victim in the felonious

assault offense was . . . a specific, targeted victim, while the victim in the discharge of a

firearm on or near prohibited premises offense . . . was the public at large,” so “the trial

court did not err in not merging the two offenses”); State v. Anderson, 2021-Ohio-2316, ¶

39 (5th Dist.) (because “the public is the victim” of an R.C. 2923.162(A)(3) discharging-a-

firearm offense, that crime “does not merge with felonious assault”); State v. Wood, 2020-

Ohio-4895, ¶ 54 (10th Dist.) (“Appellant's act of firing gunshots on a public roadway . . .

harmed the public at large, . . . [while his] conviction for felonious assault required harm

to particular victims, . . . and thus differed in the significance and nature of the harm it

addressed”); In re T.P.-A., 2019-Ohio-2038, ¶ 18 (2d Dist.) (finding offenses did not merge

because “L.M. was the victim of the felonious assault, and the public at large was the

victim of the improper discharge [of a firearm] offense” and the defendant’s “act of firing a handgun across the roadway itself violated the statute, placed numerous people at risk,

and harmed the public at large”) (internal quotations and citation omitted); State v.

Johnson, 2018-Ohio-1387, ¶ 30 (8th Dist.) (“Johnson's discharging a firearm into a

habitation, felonious assault, and discharging a firearm on or near a prohibited premises

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Related

State v. Williams
2012 Ohio 5699 (Ohio Supreme Court, 2012)
State v. Ford
2011 Ohio 765 (Ohio Supreme Court, 2011)
State v. James
2015 Ohio 4987 (Ohio Court of Appeals, 2015)
State v. Johnson
2018 Ohio 1387 (Ohio Court of Appeals, 2018)
State v. Johnson
2019 Ohio 4265 (Ohio Court of Appeals, 2019)
State v. Anderson
2021 Ohio 2316 (Ohio Court of Appeals, 2021)
State v. Roberts
2023 Ohio 142 (Ohio Court of Appeals, 2023)
State v. Henry
2025 Ohio 774 (Ohio Court of Appeals, 2025)
State v. Logan
2025 Ohio 1772 (Ohio Supreme Court, 2025)

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Bluebook (online)
2026 Ohio 235, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hoffer-ohioctapp-2026.