State v. Hutchins

2025 Ohio 1831
CourtOhio Court of Appeals
DecidedMay 22, 2025
Docket114261
StatusPublished

This text of 2025 Ohio 1831 (State v. Hutchins) 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. Hutchins, 2025 Ohio 1831 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Hutchins, 2025-Ohio-1831.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 114261 v. :

NICHOLAS HUTCHINS, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: May 22, 2025

Criminal Appeal from the Cuyahoga County Common Pleas Court Case No. CR-24-688046-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Liam E. Blake, Assistant Prosecuting Attorney, for appellee.

Wegman Hessler Valore, Matthew O. Williams, and Dean M. Valore, for appellant.

ANITA LASTER MAYS, J.:

{¶1} Defendant-appellant Nicholas Hutchins (“Hutchins”) appeals the

constitutionality of the mandatory-bindover statutes and his sentence pursuant to

the Reagan Tokes Law. We affirm. I. Facts and Procedural History

{¶2} A complaint was filed against Hutchins in the Cuyahoga County Court

of Common Pleas, Juvenile Division, alleging offenses that if committed by an

adult would constitute one count of aggravated robbery, three counts of robbery,

one count of assault, and one count of theft. The aggravated robbery and robbery

counts each carried one- and three-year firearm specifications. R.C.

2152.02(BB)(1) categorizes aggravated robbery as a category-two offense. Because

Hutchins was 16 years old and employed a firearm during the commission of a

category-two offense, transfer to the Cuyahoga County Court of Common Pleas,

General Division, is mandatory under R.C. 2152.10(A)(2)(b).

{¶3} After being bound over, Hutchins pleaded guilty to an amended count

of aggravated robbery, a first-degree felony, in violation of R.C. 2911.031(A)(1) with

a one-year firearm specification. The other five charges were nolled. Hutchins was

sentenced to four to six years’ imprisonment on the amended aggravated-robbery

count, in accordance with the Reagan Tokes Law. He was also sentenced to one

year in prison to be served prior to and consecutive to the amended aggravated

robbery count for the firearm specification for a total of five to seven years’

imprisonment.

{¶4} Hutchins filed this appeal assigning three errors for our review:

1. The trial court erred in binding appellant over from the Juvenile Division to the General Division pursuant to R.C. 2152.10 because it violates his due process rights; 2. The trial court erred in binding appellant over because R.C. 2152.10 violates his right to equal protection; and

3. The trial court committed reversible error prejudicing appellant when it imposed an unconstitutional sentence upon appellant pursuant to the Reagan Tokes Law, which is unconstitutional on its face.

II. Unconstitutionality of Statutes

A. Standard of Review

{¶5} “We review the challenge to the constitutionality of a statute de novo.”

State v. Parker, 2022-Ohio-1164, ¶ 9 (8th Dist.), citing State v. Hacker, 2020-

Ohio-5048, ¶ 12 (3d Dist.). “‘De novo review is independent, without deference to

the lower court’s decision.’” (Internal citations omitted.) Id., quoting In re K.S.G.,

2020-Ohio-4515, ¶ 37 (3d Dist.).

{¶6} “‘There are two primary ways to challenge the constitutionality of a

statute: by facial challenge or through an as-applied challenge.’” Id. at ¶ 10,

quoting Derrico v. State, 2019-Ohio-1767, ¶ 17 (8th Dist.), citing Harrold v.

Collier, 2005-Ohio-5334, ¶ 37. “When challenging the statute facially, the

appellant must demonstrate that there does not exist a set of facts whereas the

statute can be deemed constitutional.” Id., citing id. “However, an ‘as-applied’

challenge argues that when applied to a certain set of facts, the statute is

unconstitutional.” Id., citing id. “‘Facial challenges present a higher hurdle than

as-applied challenges because, in general, for a statute to be facially

unconstitutional, it must be unconstitutional in all applications.’” Id., quoting State v. Romage, 2014-Ohio-783, ¶ 7, citing Oliver v. Cleveland Indians Baseball

Co. Ltd. Partnership, 2009-Ohio-5030, ¶ 13.

{¶7} “Enactments of the General Assembly enjoy a strong presumption of

constitutionality.” Parker at ¶ 11. See, e.g., State v. Hollis, 2020-Ohio-5258, ¶ 52

(8th Dist.) (“[I]n determining whether a statute is constitutional, this court

presumes constitutionality.”). “‘This presumption requires substantial deference

to legislative judgments.’” Id., quoting Derrico at ¶ 18, citing Conley v. Shearer,

64 Ohio St.3d 284, 289 (1992). “‘It also means that courts refrain from judging the

wisdom, fairness, or logic of legislative choices.’” Id., quoting Derrico at id., citing

Heller v. Doe, 509 U.S. 312, 319 (1993). “‘Rather, courts must uphold a challenged

statute if at all possible.’” Id., quoting Derrico at id., citing Conley at id.

{¶8} “‘It is difficult to prove that a statute is unconstitutional. All statutes

have a strong presumption of constitutionality.’” Parker at ¶ 12, quoting Groch v.

GMC, 2008-Ohio-546, ¶ 25. “‘Before a court may declare unconstitutional an

enactment of the legislative branch, it must appear beyond a reasonable doubt that

the legislation and constitutional provisions are clearly incompatible.’” Id.,

quoting id., quoting State ex rel. Dickman v. Defenbacher, 164 Ohio St. 142 (1955),

paragraph one of the syllabus.

B. Law and Analysis

{¶9} In Hutchins’s first and second assignments of error, he argues that his

bindover pursuant to R.C. 2152.10 violates his due-process and equal-protection rights. Hutchins did not raise this argument to the trial court. “Generally, ‘[i]f the

defendant failed to raise an error affecting substantial rights at trial, an appellate

court reviews the error under the plain error standard in Crim.R. 52(B).’” State v.

Pugh, 2022-Ohio-3038, ¶ 17 (8th Dist.), quoting State v. Perry, 2004-Ohio-297,

¶ 14. “‘A plain error is obvious and prejudicial although neither objected to nor

affirmatively waived which, if permitted, would have a material adverse effect on

the character and public confidence in judicial proceedings.’” Id., quoting Schade

v. Carnegie Body Co., 70 Ohio St.2d 207, 209 (1982).

{¶10} “Crim.R. 52 affords appellate courts ‘limited power’ to correct plain

errors that occurred during the trial court proceeding.’” Id. at ¶ 18, citing Perry at

¶ 9. “Crim.R. 52(B) provides that ‘[p]lain errors or defects affecting substantial

rights may be noticed although they were not brought to the attention of the

court.’” Id., quoting Crim.R. 52(B). “Under the plain-error standard, ‘the

defendant bears the burden of showing that but for a plain or obvious error, the

outcome of the proceeding would have been otherwise, and reversal must be

necessary to correct a manifest miscarriage of justice.’” Id., quoting State v. West,

2022-Ohio-1556, ¶ 22. “‘An appellate court has discretion to notice plain error and

therefore is not required to correct it.’” Id., citing State v. Rogers, 2015-Ohio-2459,

¶ 23.

{¶11} Hutchins contends that his due-process rights were violated when he

was transferred to the General Division without an opportunity to be heard and without consideration of his individual circumstances and characteristics. He

asserts that mandatory bindover statutes are based upon a statutory formula

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Related

Heller v. Doe Ex Rel. Doe
509 U.S. 312 (Supreme Court, 1993)
State v. Romage
2014 Ohio 783 (Ohio Supreme Court, 2014)
Oliver v. Cleveland Indians Baseball Co. Ltd. Partnership
2009 Ohio 5030 (Ohio Supreme Court, 2009)
State v. Aalim (Slip Opinion)
2017 Ohio 2956 (Ohio Supreme Court, 2017)
State v. Taylor
2018 Ohio 3998 (Ohio Court of Appeals, 2018)
Derrico v. State
2019 Ohio 1767 (Ohio Court of Appeals, 2019)
In re Change of Name K.S.G. to K.S.G-B.
2020 Ohio 4515 (Ohio Court of Appeals, 2020)
State v. Delvallie
2022 Ohio 470 (Ohio Court of Appeals, 2022)
State v. Parker
2022 Ohio 1164 (Ohio Court of Appeals, 2022)
State v. West
2022 Ohio 1556 (Ohio Supreme Court, 2022)
Schade v. Carnegie Body Co.
436 N.E.2d 1001 (Ohio Supreme Court, 1982)
Conley v. Shearer
595 N.E.2d 862 (Ohio Supreme Court, 1992)
State v. Pugh
2022 Ohio 3038 (Ohio Court of Appeals, 2022)

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Bluebook (online)
2025 Ohio 1831, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hutchins-ohioctapp-2025.