State v. Knauff

2025 Ohio 3046
CourtOhio Court of Appeals
DecidedAugust 21, 2025
Docket23CA29
StatusPublished

This text of 2025 Ohio 3046 (State v. Knauff) 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. Knauff, 2025 Ohio 3046 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Knauff, 2025-Ohio-3046.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT ROSS COUNTY

STATE OF OHIO, : : Case No. 23CA29 Plaintiff-Appellee, : : v. : DECISION AND JUDGMENT : ENTRY JOSHUA KNAUFF, : : RELEASED: 08/21/2025 Defendant-Appellant. :

APPEARANCES:

Brian A. Smith, Brian A. Smith Law Firm, LLC, Fairlawn, Ohio, for appellant.

Jeffrey C. Marks, Ross County Prosecuting Attorney, Chillicothe, Ohio for appellee.

Wilkin, J.

{¶1} This is an appeal from a Ross County Court of Common Pleas

judgment entry that sentenced Joshua Knauff (“Knauff”) to an aggregate, 15-year

prison sentence for pleading guilty to three counts of kidnapping, which were

first-degree felonies and three counts of felonious assault, which were second-

degree felonies.

{¶2} In his sole assignment of error, Knauff asserts that a portion of his

sentence is contrary to law because the court failed to advise him of his eligibility

for earned days of credit pursuant to R.C. 2967.193. Knauff prays for this court

to modify his sentence to indicate that he is eligible for days of credit under R.C.

2967.193, or remand this matter for the trial court to make that modification. Ross App. No. 23CA29 2

Because we find that Knauff’s sentence is not contrary to law, we overrule his

assignment of error and affirm his sentence.

BACKGROUND

{¶3} On January 27, 2023, the State charged Knauff with eight counts of

kidnapping, which were first-degree felonies; three counts of rape, which were

first-degree felonies; four counts of felonious assault, which were second-degree

felonies; and one count of abduction, which was a third-degree felony.

{¶4} During an October 23, 2023 hearing, Knauff pleaded guilty to three

counts of kidnapping and three counts of felonious assault. The State dropped

the remaining charges. Immediately after Knauff’s guilty plea, the court

sentenced him to eight years in prison for each of the three kidnapping counts,

and seven years in prison for each of the three assault counts. The court

ordered the prison terms for the kidnapping to run concurrently, and the prison

terms for assault to run concurrently. However, the court ordered the prison

terms for kidnapping and the prison terms for felonious assault to be served

consecutively, for an aggregate prison term of 15 years, which was an agreed

sentence. Knauff appeals his sentence.

ASSIGNMENT OF ERROR

THE PORTION OF THE TRIAL COURT’S SENTENCE, FAILING TO ADVISE APPELLANT OF HIS ELIGIBILITY FOR EARNED DAYS OF CREDIT ON HIS SENTENCE, PURSUANT R.C. 2967.193, WAS CONTRARY TO LAW.

{¶5} Knauff maintains that his sentence should be modified because it is

contrary to law. Knauff claims that he should be eligible to receive earned days

of credit (aka good-time credit) under R.C. 2967.193. He argues that the “plea Ross App. No. 23CA29 3

form” that he signed stated that the prison term imposed “will be served without

good time credit.” He claims that at his sentencing the trial court was required to

inform him on the record that he was eligible for earned days of credit pursuant to

R.C. 2967.193, but it failed to do so.

{¶6} Knauff acknowledges that his guilty plea involved an agreed

sentence, which typically cannot be appealed. However, Knauff asserts that

even agreed sentences are appealable, if they are contrary to law. Knauff claims

that his “plea form” erroneously stated that his prison sentence would not be

eligible for earned credit under R.C. 2967.193. Because of this error, he claims

that the court was required to advise him of his eligibility for earned credit but

failed to do so. Because of these errors, Knauff claims that portion of his

sentence is contrary to law making it subject to appeal even though it was an

agreed upon sentence. Therefore, Knauff maintains that portion of his sentence

should be modified to indicate that he is eligible for good-time credit pursuant to

R.C. 2967.193.

{¶7} In response, the State maintains that the trial court did not err in

sentencing Knauff. The State claims that because the sentence was agreed to

by the parties, it is not subject to appeal pursuant to R.C. 2953.08(D)(1). Further,

the State asserts that it is the Department of Rehabilitation and Corrections that

determines a prisoner’s eligibility for, and applies earned credit, not the court.

Finally, the State claims that the law does not require the court to inform a

defendant regarding their eligibility for earned credit. Therefore, the State urges

this court to reject Knauff’s argument and affirm Knauff’s sentence. Ross App. No. 23CA29 4

Law

Standard of Review

{¶8} “R.C. 2953.08(A)(4) provides that: ‘In addition to any other right to

appeal and except as provided in division (D) of this section, a defendant who is

convicted of or pleads guilty to a felony may appeal as a matter of right the

sentence imposed upon the defendant on one of the following grounds: * * * (4)

The sentence is contrary to law.’ ” State v. McFarland, 2023-Ohio-3499, ¶ 13

(4th Dist.). However, R.C. 2953.08(D)(1) provides that “[a] sentence imposed

upon a defendant is not subject to review under this section if the sentence is

authorized by law, has been recommended jointly by the defendant and the

prosecution in the case, and is imposed by a sentencing judge.” Id.

Consequently, if an imposed, agreed sentence is ‘contrary to law[,]’ [it] is

appealable by a defendant[.]” State v. Underwood, 2010-Ohio-1, ¶ 16.

{¶9} The Supreme Court has recognized that “ ‘contrary to law’ [means] ‘in

violation of statute or legal regulations at a given time[.]’ ” State v. Jones, 2020-

Ohio-6729, ¶ 34, quoting Black's Law Dictionary 328 (6th Ed.1990). Therefore, “

‘a sentence is generally not contrary to law if the trial court considered the R.C.

2929.11 purposes and principles of sentencing as well as the R.C. 2929.12

seriousness and recidivism factors, properly applied post-release control, and

imposed a sentence within the statutory range.’ ” State v. Ogden, 2025-Ohio-

1168, ¶ 12 (4th Dist.), quoting State v. Allen, 2021-Ohio-648, ¶ 14 (4th Dist.). Ross App. No. 23CA29 5

Earned Credit

{¶10} “R.C. 2967.193 provides opportunities for inmates to earn credit

towards the satisfaction of his or her prison term ‘for participation in certain

programs.’ ” State v. Eitzman, 2022-Ohio-574, ¶ 28-33 (3rd Dist.), quoting R.C.

2967.193.

Under R.C. 2967.193, the department of rehabilitation and correction is charged with determining the amount of credit earned and awarding that credit to the prisoner. Likewise, the statute authorizes the department to deny the prisoner the right to earn credit or withdraw credits previously earned if it determines the prisoner has violated prison rules.

Id., citing State v. Livingston, 2014-Ohio-1637, ¶ 7 (1st Dist.).

However, “there is nothing in R.C. 2967.193 or elsewhere in the law that

authorizes a court to limit an offender's ability to earn days of credit.” Livingston.

at ¶ 9.

{¶11} R.C. 2967.193(A)(2) and R.C. 2967.193(A)(3) set forth earned-

credit opportunities for inmates by participating in various prison programs. See

Eitzman, ¶ 36, citing former R.C. 2967.193(A)(1) and (2), now R.C.

2967.193(A)(2) and (3).

{¶12} An inmate is ineligible to earn credit under R.C. 2967.193(A)(3) if he

or she “is serving a . .

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Related

State v. Miller
2010 Ohio 5705 (Ohio Supreme Court, 2010)
State v. Underwood
2010 Ohio 1 (Ohio Supreme Court, 2010)
State v. Livingston
2014 Ohio 1637 (Ohio Court of Appeals, 2014)
State v. Allen
2021 Ohio 648 (Ohio Court of Appeals, 2021)
State v. Eitzman
2022 Ohio 574 (Ohio Court of Appeals, 2022)
State v. McFarland
2023 Ohio 3499 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 3046, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-knauff-ohioctapp-2025.