State v. Leach

2024 Ohio 978
CourtOhio Court of Appeals
DecidedMarch 15, 2024
Docket2023-CA-34
StatusPublished
Cited by1 cases

This text of 2024 Ohio 978 (State v. Leach) 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. Leach, 2024 Ohio 978 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Leach, 2024-Ohio-978.]

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

STATE OF OHIO : : Appellant : C.A. No. 2023-CA-34 : v. : Trial Court Case No. 2022 CR 179 : JAMES M. LEACH, JR. : (Criminal Appeal from Common Pleas : Court) Appellee : :

...........

OPINION

Rendered on March 15, 2024

MEGAN A. HAMMOND, Attorney for Appellant

JOHN A. FISCHER, Attorney for Appellee

.............

WELBAUM, J.

{¶ 1} The State appeals from a judgment imposing prison terms on Defendant-

Appellee James Leach, Jr., and awarding him jail-time credit toward those terms.

According to the State, the trial court erred in crediting Leach with 303 days of jail-time

credit. We agree. While Leach was being held on bond in the current case, he was -2-

serving prison time on an unrelated case, and jail-time credit is not allowed in this

situation. Further, the trial court ordered the sentences in this case to be served

consecutively to those in the unrelated case, and jail-time credit is also not allowed in that

situation.

{¶ 2} Accordingly, the trial court’s judgment will be reversed only as to the award

of jail-time credit. This case will be remanded for the trial court to file a new judgment

entry omitting the jail-time credit and for it to notify the Ohio Department of Rehabilitation

and Corrections (“ODRC”) of the change.

I. Facts and Course of Proceedings

{¶ 3} On April 29, 2022, Leach was indicted in the Greene County Court of

Common Pleas on seven felony counts arising from events that occurred on April 21,

2022. The charges included: two counts of felonious assault, second-degree felonies;

abduction, a third-degree felony; aggravated burglary (with a firearm specification), a first-

degree felony; grand theft, a third-degree felony; vandalism, a fourth-degree felony; and

inducing panic, a fifth-degree felony. A warrant on the indictment was served on Leach

at the Montgomery County Jail on May 2, 2022.

{¶ 4} At the time, Leach was in custody for charges brought against him in

Montgomery C.P. No. 2022 CR 01157. These charges were based on events that also

took place on April 21, 2022, but occurred in Montgomery County, Ohio. The charges

were two counts of failure to comply with an order or signal of police officer (serious -3-

physical risk or substantial risk of harm), third-degree felonies.1 On May 3, the court in

that case set bond of $5,000, and Leach remained in jail until disposition. Leach pled

guilty to one of the charges on May 16, 2022, and on May 31, 2022, the court filed a

judgment entry sentencing him to 24 months in prison and granting 36 days of jail time

credit up to the date of sentencing. State v. Leach, Montgomery C.P. No. 2022 CR

01157 (May 31, 2022) (“Case No. 01157”), p. 1, https://pro.mcohio.org (accessed on

February 5, 2024).

{¶ 5} On June 3, 2022, the court in the current case entered a not guilty plea for

Leach, set bond at $100,000 C/S GPS/Electronic Home Arrest Level II, and set trial for

August 1, 2022. Leach was conveyed to prison on the prior conviction on June 15, 2022.

ODRC then gave Leach 54 total days of jail-time credit and calculated his release date to

be April 24, 2024. See Case No. 01157, Notice of Commitment (July 8, 2022).

{¶ 6} Subsequently, the August trial date in the current case was continued and

trial was set for November 14, 2022. After Leach filed a motion to suppress, the court

continued the trial date and set a November 9, 2022 hearing on the motion. However,

on November 9, 2022, Leach appeared in court and pled guilty to counts 2, 4, 5, and 6 of

the indictment (felonious assault, aggravated burglary, grand theft, and vandalism); the

State agreed to dismiss the remaining counts and specifications. Transcript of

1 We note that appellate courts commonly “take judicial notice of publically accessible

online court dockets.” State v. Estridge, 2d Dist. Miami No. 2021-CA-25, 2022-Ohio-208, ¶ 12, fn. 1, citing State v. McClurg, 2d Dist. Darke No. 2019-CA-15, 2020-Ohio-1144, ¶ 8. See also State ex rel. Everhart v. McIntosh, 115 Ohio St.3d 195, 2007-Ohio-4798, 874 N.E.2d 516, ¶ 8 and 10 (finding that a court can take judicial notice of appropriate matters, including judicial opinions and public records accessible from the internet). As a result, we may consult the Montgomery County Common Pleas Court records and the ODRC records, which are both public records and are readily accessible on the internet. -4-

Proceedings (Change of Plea Hearing) (“Plea Tr.”), 12-13. There was no agreement

regarding sentencing. Id. at 16. The trial court noted that if it chose to impose a prison

term, any prison term would run consecutively to Leach's sentence in Case No. 01157.

Id. at 17 and 20-22.

{¶ 7} During the plea hearing, the court ordered the defense to submit any brief

about sentencing and merger by three weeks before sentencing. The State would then

have a week to respond. Id. at 25. After the court explained Leach's rights, Leach pled

guilty, and the court found him guilty of the four counts. Id. at 40-41. The court then set

disposition for December 15, 2022.

{¶ 8} On November 21, 2022, Leach filed a sentencing memorandum, and the

State responded on November 29, 2022. The State attached the May 31, 2022

termination entry from Case No. 01157 to its memorandum as Ex. 2. In that entry, as

noted, the court had sentenced Leach to a 24-month prison term and had given him 34

days of jail-time credit.

{¶ 9} Ultimately, a sentencing hearing in the current case was held on February 8,

2023. However, during the hearing, the court said it needed more time to review the

sentencing memoranda. Plea Tr. at 45. The court also reopened the plea hearing to

correct a technical error, i.e., to inform Leach that he would be eligible for community

control. Id. at 45-46. Leach then affirmed that he wished to maintain his guilty pleas as

indicated in the November 9, 2022 plea colloquy. Id. at 46. The court filed an amended

judgment entry to that effect on February 8, 2023.

{¶ 10} During the May 31, 2023 sentencing hearing, the parties agreed that the -5-

sentence in the current case would run consecutively to the Montgomery County

sentence by operation of law. Transcript of Proceedings (Final Disposition Hearing)

(“Disp. Tr.”), 4. At that time, the court also found counts 4 and 5 were allied offenses

and merged them, and the State elected sentencing on count 4 (aggravated burglary).

Id. at 5. The court then sentenced Leach as follows: on count 2, an indefinite sentence

of a minimum of four years to a maximum of six years; on count 4, an indefinite sentence

of a minimum of four years to a maximum of six years; and on count six, a definite

sentence of six months. Id. at 6. The court imposed the term for count 2 concurrently

with the term for count 4, and imposed the definite term in count 6 consecutively, for an

aggregate minimum term of 4.5 years and a maximum term of 6.5 years. Id.

{¶ 11} The court further stated that Leach’s sentence would run consecutively to

the sentence from Montgomery County, Ohio. Id. at 7. In addition, the court said it

would credit Leach with 330 days of jail-time credit by operation of law. Id. However,

during the hearing, the State raised an issue about this. Id.

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Bluebook (online)
2024 Ohio 978, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-leach-ohioctapp-2024.