State v. Hurley

2025 Ohio 5432
CourtOhio Court of Appeals
DecidedDecember 5, 2025
Docket2024-CA-25
StatusPublished

This text of 2025 Ohio 5432 (State v. Hurley) 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. Hurley, 2025 Ohio 5432 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Hurley, 2025-Ohio-5432.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CHAMPAIGN COUNTY

STATE OF OHIO : : C.A. No. 2024-CA-25 Appellee : : Trial Court Case No. 2024 CR 078 v. : : (Criminal Appeal from Common Pleas BLAYDEN JAMES DANIEL HURLEY : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on December 5, 2025, the judgment of

the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

LEWIS, J., and HANSEMAN, J., concur. OPINION CHAMPAIGN C.A. No. 2024-CA-25

RICHARD L. KAPLAN, Attorney for Appellant SAMANTHA B. WHETHERHOLT, Attorney for Appellee

TUCKER, J.

{¶ 1} Bladen James Daniel Hurley appeals from his convictions of aggravated

vehicular assault and operating a motor vehicle while under the influence of alcohol (“OVI”).

{¶ 2} Hurley challenges the trial court’s failure to find his offenses subject to merger

as allied offenses of similar import. He also claims the record does not support the trial

court’s imposition of a five to seven-and-a-half-year prison sentence for aggravated

vehicular assault.

{¶ 3} We conclude that merger did not apply and that the record supports the

challenged sentence. Accordingly, the trial court’s judgment is affirmed.

I. Background

{¶ 4} A grand jury indicted Hurley on two counts of OVI, two counts of improperly

handling a firearm in a motor vehicle, one count of aggravated vehicular assault, and one

count of vehicular assault. The charges stemmed from Hurley crashing his vehicle into a

tree and injuring a passenger on June 9, 2024 after drinking and tubing on a nearby river.

The weapons charges involved two firearms discovered in his car at the scene. He pled

guilty to aggravated vehicular assault, a second-degree felony, and one count of OVI, a first-

degree misdemeanor, in exchange for dismissal of the other charges. He also agreed to

forfeit certain property. Finally, he agreed to pay court costs and court-appointed legal fees.

The trial court accepted the plea agreement and made findings of guilt.

2 {¶ 5} The case proceeded to an October 23, 2024 sentencing hearing. Based on its

review of the record, including a presentence investigation report, the trial court imposed an

indefinite prison sentence of five to seven-and-a-half years for aggravated vehicular assault

and a concurrent six-month jail term for OVI. Hurley timely appealed, advancing two

assignments of error.

II. Analysis

{¶ 6} The first assignment of error states:

THE TRIAL COURT VIOLATED MR. HURLEY’S DOUBLE JEOPARDY

RIGHTS WHEN IT HELD HIS PLEAS TO OVI AND AGGRAVATED

VEHICULAR ASSAULT WERE NOT CRIMES OF SIMILAR IMPORT SO AS

TO BE MERGED.

{¶ 7} Applying a familiar three-part test from State v. Ruff, 2015-Ohio-995, Hurley

contends the trial court erred in failing to merge OVI and aggravated vehicular assault as

allied offenses of similar import. He asserts that the existence of an OVI offense was an

element of aggravated vehicular assault. He argues that both offenses involved the same

act committed at the same time and that the only motive for both offenses “was to drive to a

specific place.” As a result, Hurley claims that merger applied and that he should have been

sentenced for one offense.

{¶ 8} Upon review, we conclude that the trial court correctly declined to merge the

two offenses. In State v. Earley, 2015-Ohio-4615, the Ohio Supreme Court applied Ruff and

rejected the argument Hurley raises. It held that OVI and aggravated vehicular assault do

not merge because they are “of dissimilar import and significance.” Id. at ¶ 13. “[A]ggravated

vehicular assault necessarily involves causing serious physical harm to another person,”

whereas OVI “occurs any time an individual drives under the influence of alcohol or drugs,

3 and one who does so commits this offense regardless of any subsequent consequences

that occur due to the impaired driver’s actions.” Id. at ¶ 15. The Earley court found that

“[t]here is a legitimate justification for criminalizing each of these offenses separately, and

R.C. 2941.25 permits separate convictions for both pursuant to the test set forth in Ruff.” Id.

Accordingly, the first assignment of error is overruled.

{¶ 9} The second assignment of error states:

THE TRIAL COURT ERRED WHEN IT SENTENCED MR. HURLEY TO A

PRISON SENTENCE MINIMUM OF FIVE (5) YEARS TO A MAXIMUM OF

SEVEN AND ONE-HALF (7.5) YEARS ON THE CONVICTION FOR

AGGRAVATED VEHICULAR ASSAULT.

{¶ 10} Hurley challenges the trial court’s imposition of a five to seven-and-a-half-year

prison sentence for aggravated vehicular assault. He argues that the sentence was imposed

based on improper considerations, including (1) his involvement in an unrelated 2001 traffic

accident, (2) an unsupported finding that he had two prior convictions for driving under

financial-responsibility suspension, and (3) an undocumented finding that his blood-alcohol

content in this case was .195 g/210L. He also argues that the trial court did not adequately

consider his prior law-abiding life or the fact that the injured victim in this case also had been

drinking and voluntarily got into his car. Hurley raises his sentencing argument in the context

of R.C. 2929.12, which identifies factors for a trial court to consider that tend to make an

offense more or less serious and recidivism more or less likely.

{¶ 11} “When reviewing felony sentences, appellate courts must apply the standard

of review set forth in R.C. 2953.08(G)(2).” State v. Evans, 2023-Ohio-3656, ¶ 8 (2d Dist.),

citing State v. Marcum, 2016-Ohio-1002, ¶ 7. “Under that statute, an appellate court may

increase, reduce, or modify a sentence, or it may vacate the sentence and remand for

4 resentencing, only if it clearly and convincingly finds either: (1) the record does not support

the sentencing court’s findings under certain statutes . . . or (2) the sentence is otherwise

contrary to law.” Id., citing Marcum at ¶ 9. The two subsections involved are

R.C. 2953.08(G)(2)(a) and (b).

{¶ 12} We note that R.C. 2953.08(G)(2)(a) “does not allow an appellate court to

modify or vacate a sentence based on its view that the sentence is not supported by the

record” under R.C. 2929.12. State v. Bryant, 2022-Ohio-1878, ¶ 22. Because R.C. 2929.12

is not among the statutes listed in R.C. 2953.08(G)(2), we may not “look behind” a trial

court’s sentencing decision to determine whether the record supports its analysis of the

statutory seriousness and recidivism factors. State v. Orr, 2024-Ohio-4707, ¶ 12 (2d Dist.).

{¶ 13} A sentence also generally is not “contrary to law” under R.C. 2953.08(G)(2)(b)

even if the record fails to support a trial court’s analysis of the seriousness and recidivism

factors. Id. at ¶ 13. An exception applies where a trial court relies on “‘factors or

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Related

State v. Marcum (Slip Opinion)
2016 Ohio 1002 (Ohio Supreme Court, 2016)
State v. Bryant
2022 Ohio 1878 (Ohio Supreme Court, 2022)
State v. Evans
2023 Ohio 3656 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5432, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hurley-ohioctapp-2025.