State v. Lawson

Ohio Court of Appeals·Decided August 21, 2026·No. 2025CA00050·Published

Opinion

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT

FAIRFIELD COUNTY, OHIO

STATE OF OHIO Case No. 2025CA00050 Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Court of Common Pleas, Case No. 2022 CR 173

RAFFAEL LAWSON Judgment: Affirmed

Defendant - Appellant Date of Judgment Entry: August 21, 2026

BEFORE: Andrew J. King; Robert G. Montgomery; Kevin W. Popham, Judges

APPEARANCES: R. KYLE WITT, MARK A. BALAZIK, for Plaintiff-Appellee; ALLISON F. HIBBARD, for Defendant-Appellant.

King, P.J.

{¶ 1} Defendant-Appellant Raffael Lawson appeals the November 24, 2025 judgment of the Fairfield County Court of Common Pleas which denied his motion for postconviction relief. Plaintiff-Appellee is the State of Ohio. We affirm the trial court.

Facts and Procedural History

{¶ 2} In February and April of 2022, Lawson was involved in two separate instances of using drones to drop drugs into the prison yards at the Richland County Correctional Institution and the Southeastern Correctional Institution in Fairfield County. He was later charged with 17 felonies and one misdemeanor in connection with these activities.

{¶ 3} Following a jury trial, Lawson was convicted on 15 felony counts and the misdemeanor. He was sentenced to a 12-year prison term.

{¶ 4} Lawson timely appealed and this court found the state had failed to produce sufficient evidence of one of those felonies — engaging in a pattern of corrupt activity — and trial court had failed to fully advise him about the indefinite-sentencing process in Ohio. We vacated Lawson's conviction on count one of the indictment, engaging in a pattern of corrupt activity, and further remanded the matter for a resentencing hearing in accordance with R.C. 2929.19(B)(2)(c) on count six of the indictment, aggravated trafficking. State v. Lawson, 2025- Ohio-934 (5th Dist.).

{¶ 5} On August 21, 2025, Lawson timely filed a motion for postconviction relief raising two claims of constitutional error, specifically: 1.) Ineffective assistance of trial counsel for failing to investigate and call his nephew, Darius Lawson as a witness at trial and 2.) a chain-of-custody argument regarding Sergeant Robinson's alleged failure to enter a seized cell phone into evidence.

{¶ 6} On November 24, 2025, the trial court dismissed Lawson's petition without a hearing. This appeal followed. Lawson raises three assignments of error as follows:

I

{¶ 7} "THE TRIAL COURT ERRED IN FAILING TO HOLD AN EVIDENTIARY HEARING ON APPELLANT'S PETITION FOR POST-CONVICTION RELIEF."

II

{¶ 8} "THE TRIAL COURT ABUSED ITS DISCRETION IN DENYING APPELLANT'S PETITION FOR POST-CONVICTION RELIEF AS APPELLANT ESTABLISHED A CONSTITUTIONAL VIOLATION."

III

{¶ 9} "THE TRIAL COURT ERRED IN CONSIDERING THE STATE'S OPPOSITION AND ATTACHED SUPPORTING EVIDENCE, AS IT WAS UNTIMELY SUBMITTED AND NO GOOD CAUSE EXISTED FOR EXPANDING THE TIME TO FILE A RESPONSE."

I, II

{¶ 10} We address Lawson's first and second assignments of error together. In these assignments of error, Lawson argues the trial court erred in denying his petition without a hearing. We disagree.

Standard of Review

{¶ 11} An appellate court reviews a trial court's denial of a petition for post-conviction relief without a hearing under an abuse of discretion standard. State v. Watson, 126 Ohio App. 3d 316, 324 (1988). "Abuse of discretion" means an attitude that is unreasonable, arbitrary or unconscionable. Huffman v. Hair Surgeon, Inc., 19 Ohio St.3d 83, 87 (1985). Most instances of abuse of discretion will result in decisions that are simply unreasonable, rather than decisions that are unconscionable or arbitrary. AAAA Ent., Inc. v. River Place Community Urban Redev. Corp., 50 Ohio St.3d 157, 161 (1990). An unreasonable decision is one backed by no sound reasoning process that would support that decision. Id. "It is not enough that the reviewing court, were it deciding the issue de novo, would not have found that reasoning process to be persuasive, perhaps in view of countervailing reasoning processes that would support a contrary result." Id.

Postconviction Relief Principles

{¶ 12} Although designed to address claimed constitutional violations, the post-

conviction relief process is a civil collateral attack on a criminal judgment, not an appeal of that judgment. State v. Calhoun, 86 Ohio St.3d 279, 281 (1999); State v. Steffen, 70 Ohio St.3d 399, 410 (1994). A petition for post-conviction relief does not provide a petitioner a second opportunity to litigate his conviction, nor is the petitioner automatically entitled to an evidentiary hearing on the petition. State v. Lewis, 2008-Ohio-3113, ¶ 8 (5th Dist.), citing State v. Jackson, 64 Ohio St.2d 107, 110 (1980).

{¶ 13} Regarding Lawson's entitlement to a hearing, a petitioner's right to a hearing is not automatic. State v. Calhoun, 86 Ohio St.3d 279, 282 (1999); State v. Jackson, 64 Ohio St.2d 107, 111 (1980). Rather, R.C. 2953.21(D) provides that before granting such a hearing, the court shall determine whether there are "substantive grounds for relief." In making that determination, "the court shall consider, in addition to the petition, the supporting affidavits, and the documentary evidence, all the files and records pertaining to the proceedings against the petitioner, including, but not limited to, the indictment, the court's journal entries, the journalized records of the clerk of the court, and the court reporter's transcript." R.C. 2953.21(F) further states the trial court must hold a prompt hearing "unless the petition and the files and records of the case show the petitioner is not entitled to relief." "[B]road assertions without a further demonstration of prejudice do not warrant a hearing for all post-conviction petitions. General conclusory allegations to the effect that a defendant has been denied effective assistance of counsel are inadequate as a matter of law to impose an evidentiary hearing." State v. Lichtenwalter, 2021-Ohio-1394, ¶ 42 (5th Dist.), citing State v. Jackson, 64 Ohio St.2d 107, 111 (1980).

{¶ 14} Lawson therefore bore the initial burden to "submit evidentiary documents containing sufficient operative facts to demonstrate . . . " "that [constitutional] errors did occur and that the errors resulted in prejudice." Calhoun at 283, quoting Jackson, supra, at syllabus; State v. Bunch, 2022-Ohio-4723, ¶ 24. If the record on its face disproves the petitioner's claims, the court may dismiss the petition without a hearing. State v. Wright, 2023-Ohio-2895, ¶ 21. In other words, the trial court performs a gatekeeping role as to whether a defendant will receive a hearing and may dismiss a petition without a hearing "where the petition, the supporting affidavits, the documentary evidence, the files, and the records do not demonstrate that petitioner set forth sufficient operative facts to establish substantive grounds for relief." State v. Calhoun, 86 Ohio St. 3d 279, paragraph two of the syllabus; State v. Clinton, 2024-Ohio- 4720, ¶¶ 17-19, quoting Bunch, ¶ 23.

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