State v. Hubal

2025 Ohio 2320
CourtOhio Court of Appeals
DecidedJune 30, 2025
Docket2024 CAA 070041
StatusPublished

This text of 2025 Ohio 2320 (State v. Hubal) 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. Hubal, 2025 Ohio 2320 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Hubal, 2025-Ohio-2320.]

COURT OF APPEALS DELAWARE COUNTY, OHIO FIFTH APPELLATE DISTRICT

: JUDGES: : Hon. Craig Baldwin, P.J. STATE OF OHIO : Hon. Michael D. Hess, V.J. : Hon. Jason Smith, V.J. Plaintiff-Appellant : : Judge Hess and Judge Smith -vs- : Sitting by Assignment of the : Supreme Court of Ohio : TIMOTHY A. HUBAL, JR. : Case No. 2024 CAA 070041 : Defendant-Appellee : OPINION

CHARACTER OF PROCEEDINGS: Appeal from the Delaware County Court of Common Pleas, Case No. 2011 CRI 10 0536

JUDGMENT: Reversed

DATE OF JUDGMENT ENTRY: June 30, 2025

APPEARANCES:

For Plaintiff-Appellant For Defendant-Appellee

MELISSA A. SCHIFFEL SPENCER CAHOON Prosecuting Attorney, Delaware County, Ohio Law Office of Spencer J. Cahoon KATHERYN L. MUNGER 800 S. Cassingham Rd. Assistant Prosecuting Attorney, Bexley, Ohio 43209 Delaware County Prosecutor’s Office 145 North Union Street, 3rd Floor Delaware, Ohio 43015 Hess, J.

{¶1} Plaintiff-Appellant State of Ohio appeals the June 25, 2024 judgment entry

of the Delaware County Common Pleas Court granting Defendant-Appellee’s motion to

withdraw his guilty plea. Defendant-Appellee is Timothy A. Hubal, Jr.

I. STATEMENT OF THE FACTS AND CASE1

{¶2} In March 2011, a Delaware County grand jury indicted Hubal on multiple

counts of rape, unlawful sexual contact with a minor, and gross sexual imposition. The

charges involved two minors. In October 2011, Hubal was indicted on additional rape and

gross sexual imposition counts, as well as one count each of felonious assault and

domestic violence. These charges arose from incidents involving a third minor, Hubal’s

stepdaughter.

{¶3} In November 2011, Hubal entered Alford pleas2 to one count of unlawful

sexual contact involving the first minor, one count of gross sexual imposition involving the

second minor, and one count of rape involving the third minor, his stepdaughter. The

remaining twenty charges were dismissed. The trial court sentenced Hubal to a jointly

recommended sentence of an aggregate term of life imprisonment with parole eligibility

after 25 years.

{¶4} In 2012, Hubal filed a motion for leave to file a delayed appeal that was

denied. In July 2023, Hubal filed a motion to vacate his conviction and to withdraw his

Alford plea. Hubal argued that his plea was induced by his trial counsel’s false

1 The procedural history is summarized from State v Hubal, 2023-Ohio-4100, ¶ 2-6 (5th Dist.). 2 An Alford plea is a guilty plea that is entered despite contentions of innocence. It may be accepted where

the validity of the plea cannot seriously be questioned in view of a strong factual basis for the plea that is demonstrated by the record. 26 Ohio Jur. 3d, Criminal Law: Procedure, § 991 (Feb. 2025 Update); North Carolina v. Alford, 400 U.S. 25, 38 (1970). representations and failure to properly investigate the evidence prior to advising him to

make the Alford plea. Among other things, Hubal attached an affidavit made in 2023 and

deposition from his stepdaughter taken in 2022, who was then 20 years old, in which she

“claimed she was coached by her mother to make false allegations against her stepfather

Hubal and he never committed the offense she accused him of.” State v. Hubal, 2023-

Ohio-4100, ¶ 6 (5th Dist.). She had made the original accusations against Hubal when

she was seven years old. The trial court denied the motion, Hubal appealed, and we

affirmed the trial court’s judgment. Id. at ¶ 40.

{¶5} In March 2024, Hubal filed a second motion to withdraw his Alford plea. He

contended that his stepdaughter, who is now an adult, has come forward with statements

that she was coerced by her mother to make false accusations against Hubal. He argued

that because the only evidence in the case was her prior statements made in 2011 when

she was seven, her recantation calls into question the entire basis of his conviction. He

also argued that his motion should not be barred by res judicata because it raises different

claims that were not adjudicated in the first motion to withdraw the Alford plea.

Specifically, his first motion was couched in terms of (1) an ineffective assistance of

counsel claim based on his trial counsel’s failure in 2011 to interview his stepdaughter

separately and discover the coercive and false nature of her statements and (2) a Brady

violation3 that the prosecutor knew of the coercion and withheld that information from the

defense. Both claims were based on alleged failures that occurred in 2011. His second

3 A Brady violation occurs when the prosecution suppresses evidence favorable to an accused, upon request, where the suppressed evidence is material either to the defendant's guilt, or to punishment of the defendant upon a guilty verdict. 25 Ohio Jur. 3d, Criminal Law: Procedure, § 376 (Feb. 2025 Update); Brady v. Maryland, 373 U.S. 83 (1963). motion was focused on events that occurred beginning in 2021, after his stepdaughter

turned 18 and culminated in her recantation of the rape allegations in her deposition in

2022.

{¶6} The State opposed Hubal’s motion on the ground that it was barred by res

judicata. The State argued that, in his prior motion to withdraw his guilty plea, Hubal

contended that his stepdaughter’s accusations were coached and coerced by her mother

and that his counsel was deficient for failing to make a full investigation of the accusations

before advising him to make an Alford plea. This motion was denied and affirmed on

appeal. Thus, the State argued Hubal cannot make a second attempt to withdraw his plea

based on the same underlying facts. The State also argued that Hubal failed to establish

a reasonable likelihood that a withdrawal of his plea is necessary to correct a manifest

injustice and a witness’s recantation is an insufficient basis to withdraw a plea.

{¶7} The trial court held a 2-day hearing on the motion at which Hubal, his

stepdaughter, her mother, Hubal’s mother, and Hubal’s 17-year-old son testified. The

stepdaughter testified that Hubal never sexually assaulted her and that the only reason

she made that allegation in 2011 was because her “mother used to coach me beforehand

and try to put in my brain that it was my stepfather doing all those things to me instead of

the men she brought in.” When the issue first came up, the stepdaughter was in foster

care and then in the custody of her grandparents. Stepdaughter testified that her mother

began coaching her after her arm was broken in October 2010, she had not shown up for

school for a long time, and the school had notified children services. Stepdaughter

explained that instead of her stepfather, it was other men that her mother brought home

who sexually assaulted her. However, her mother told her to say it was Hubal who did it because she wanted out of the relationship with him. Stepdaughter testified that she did

not have a close relationship with her mother and that she listened to her coaching and

coercion because she thought it would bring her mother closer to her.

{¶8} Stepdaughter testified that her mother never regained custody of her and

she was in the care of her paternal grandparents until age 15 when she went to the

Belmont Institute for psychiatric treatment. After staying a year at the Belmont Institute,

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
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State v. Tinney
2012 Ohio 72 (Ohio Court of Appeals, 2012)
State v. Grillo
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State v. Simpkins
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Boyd v. Boyd
2022 Ohio 4775 (Ohio Court of Appeals, 2022)
In re Resignation of Stone
2023 Ohio 129 (Ohio Supreme Court, 2023)
State v. Hubal
2023 Ohio 4100 (Ohio Court of Appeals, 2023)
State v. Howard
2024 Ohio 2410 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2320, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hubal-ohioctapp-2025.