State v. Kanyamihigo

2025 Ohio 4970
CourtOhio Court of Appeals
DecidedOctober 31, 2025
Docket2025-CA-12
StatusPublished

This text of 2025 Ohio 4970 (State v. Kanyamihigo) 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. Kanyamihigo, 2025 Ohio 4970 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Kanyamihigo, 2025-Ohio-4970.]

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

STATE OF OHIO : : C.A. No. 2025-CA-12 Appellee : : Trial Court Case No. 2024CR0101 v. : : (Criminal Appeal from Common Pleas EZEKIA DEO KANYAMIHIGO : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on October 31, 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

EPLEY, P.J., and HANSEMAN, J., concur. OPINION GREENE C.A. No. 2025-CA-12

ANTHONY D. MAIORANO, Attorney for Appellant MEGAN A. HAMMOND, Attorney for Appellee

TUCKER, J.

{¶ 1} Ezekia Deo Kanyamihigo appeals from his conviction following a guilty plea to

two counts of aggravated robbery, one count of felonious assault, and one count of having

a weapon while under disability.

{¶ 2} Kanyamihigo challenges the validity of his plea. He contends the trial court did

not advise him of the State’s burden to prove his guilt beyond a reasonable doubt, as

required by Crim.R. 11(C)(2)(c).

{¶ 3} We conclude that the trial court strictly complied with its obligation to advise

Kanyamihigo of the State’s burden of proof. Accordingly, the trial court’s judgment is

affirmed.

I. Background

{¶ 4} A grand jury indicted Kanyamihigo on five counts of aggravated robbery with

firearm specifications, one count of felonious assault with a firearm specification, and five

counts of having a weapon while under disability. After unsuccessfully moving to suppress

the evidence against him, he agreed to plead guilty to two counts of aggravated robbery,

one count of felonious assault, and one count of having a weapon while under disability. In

exchange, the State agreed to dismiss the other charges and all specifications. The State

also agreed to recommend a particular indefinite minimum prison term. The trial court

accepted the plea, made a finding of guilt, and imposed a sentence. This appeal followed.

2 II. Analysis

{¶ 5} Kanyamihigo’s assignment of error states:

The Trial Court Failed To Strictly Comply With The Advisement That The

State Is Required To Prove His Guilt Beyond A Reasonable Doubt.

{¶ 6} Kanyamihigo contends the trial court violated Crim.R. 11(C)(2)(c) at his plea

hearing by failing to advise him of the State’s obligation to prove his guilt beyond a

reasonable doubt. He correctly notes that this aspect of Crim.R. 11(C) required strict

compliance by the trial court because it involved the waiver of a constitutional right. State v.

Veney, 2008-Ohio-5200, ¶ 21. Kanyamihigo also recognizes, however, that a trial court need

not recite Crim.R. 11(C)(2)(c) verbatim. “[A] trial court can still convey the requisite

information on constitutional rights to the defendant even when the court does not provide a

word-for-word recitation of the criminal rule, so long as the trial court actually explains the

rights to the defendant.” Id. at ¶ 27. Whatever terminology a trial court employs, the required

information must be conveyed in a “reasonably intelligible” manner. Id.

{¶ 7} Here Kanyamihigo participated in his plea hearing with assistance from a

Swahili interpreter because he had limited English-language skills. During the plea colloquy,

the trial court advised him as follows regarding the State’s obligation to prove his guilt

beyond a reasonable doubt:

Now, I want to talk to you about your constitutional rights. Most notably,

your right to fight the case. And it’s not too late to do that now. We have a

potential jury out in the hallway right now, numbering over sixty; ready, willing,

and able to come in here and potentially serve as jurors for you[r] trial. That’s

called the right to a jury trial. And 12 of them would be seated in that jury box

and, before you could ever be found guilty, all 12 would have to be convinced

3 beyond a reasonable doubt that you were guilty beyond a reasonable doubt

before you could ever be found guilty; or, you could have me hear the case

under the same rules. That’s called the right to a jury trial, or a jury trial.

(Emphasis added.) July 8, 2024 Tr. 28-29.

{¶ 8} After Kanyamihigo indicated his understanding, the trial court proceeded to

advise him of other constitutional rights as follows:

Okay. Well, if you did go to trial today, as we’re prepared to do, you

would also enjoy the following rights: The presumption of innocence, meaning

that you would go into this trial presumed innocent. You would have the right

to testify on your own behalf, if you chose to do so. You and your attorney

would have the right to confront and cross examine all witnesses in the case.

You have the right of compulsory process, meaning your attorney has, and, or

would subpoena witnesses on your behalf and defense. And you could never

be forced to testify against yourself and your silence could never be used as

an attempt to prove your guilt.

(Emphasis added.) July 8, 2024 Tr. 29-30.

{¶ 9} Once again, Kanyamihigo indicated his understanding, and the trial court

accepted his plea.

{¶ 10} On appeal, Kanyamihigo stresses that Crim.R. 11(C)(2)(c) obligated the trial

court to tell him a guilty plea waives the right “to require the state to prove the defendant’s

guilt beyond a reasonable doubt.” He concedes that the trial court advised him of the jury’s

obligation to find him guilty beyond a reasonable doubt. He argues, however, that the trial

court never told him who had the burden to prove him guilty. The trial court never mentioned

“the State” or “the prosecutor” in the quoted portion of the plea colloquy.

4 {¶ 11} Upon review, we find Kanyamihigo’s argument to be unpersuasive. The trial

court advised him that he was presumed innocent and that “the jury would have to be

convinced beyond a reasonable doubt” that he was guilty. The only parties to the case were

Kanyamihigo and the State. No defendant would think he had to prove his own guilt. The

only possible “convincer” was the State. The trial court admittedly did not use the words “the

State” or “the prosecutor” to identify who had to convince the jury, but there was no one else.

Although the trial court did not recite Crim.R. 11(C)(2)(c) verbatim, it conveyed the required

information in a reasonably intelligible manner.

{¶ 12} For purposes of Kanyamihigo’s constitutional rights, the crucial information

was that a defendant cannot be convicted without proof of guilt beyond a reasonable doubt,

not the obvious fact that the State must prove its case. “Although the right to be proven guilty

by the state beyond a reasonable doubt is one of the five rights included within

Crim.R. 11(C)(2)(c),” the Ohio Supreme Court historically “never expressly accorded it the

same stature as the other four.” Veney, 2008-Ohio-5200, at ¶ 20. In Veney, however, the

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Bluebook (online)
2025 Ohio 4970, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kanyamihigo-ohioctapp-2025.