State v. Legha

2024 Ohio 3431
CourtOhio Court of Appeals
DecidedSeptember 6, 2024
Docket24-CA-08
StatusPublished

This text of 2024 Ohio 3431 (State v. Legha) 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. Legha, 2024 Ohio 3431 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Legha, 2024-Ohio-3431.]

COURT OF APPEALS FAIRFIELD COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO : JUDGES: : Hon. Patricia A. Delaney, P.J. Plaintiff-Appellee : Hon. W. Scott Gwin, J. : Hon. Andrew J. King, J. -vs- : : SAMRAT LEGHA : Case No. 24-CA-08 : Defendant-Appellant : OPINION

CHARACTER OF PROCEEDING: Appeal from the Municipal Court, Case No. 21-CRB-1475

JUDGMENT: Affirmed

DATE OF JUDGMENT: September 6, 2024

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

JOSEPH M. SABO W. JOSEPH EDWARDS 136 West Main Street 511 South High Street P.O. Box 1008 Columbus, OH 43215 Lancaster, OH 43130 Fairfield County, Case No. 24-CA-08 2

King, J.

{¶ 1} Defendant-appellant, Samrat Legha, appeals the February 21, 2024 entry

of the Municipal Court of Fairfield County, Ohio, denying his motion for leave to file a

motion for new trial without holding a hearing. Plaintiff-appellee is the State of Ohio. We

affirm the trial court.

FACTS AND PROCEDURAL HISTORY

{¶ 2} On November 13, 2021, Legha was charged with two counts of domestic

violence in violation of R.C. 2919.25 and one count of assault in violation of R.C. 2903.13.

The charges arose from an incident involving Legha and his wife.

{¶ 3} A bench trial was held on January 7, 2022. During the trial, the trial court

heard from the wife, her eleven-year-old child, and the three responding law enforcement

officers. Body cam footage was admitted. According to Legha, wife was inconsistent on

the stand; she testified that although she did make the statements to the police about

Legha's actions on the body cam footage, the footage was not an accurate depiction of

the events as she was not in the right state of mind when she made the statements. See

Appellant's Brief, Statement of the Facts, at 1-2.

{¶ 4} By verdict and entry filed February 16, 2022, the trial court found Legha

guilty as charged. By final judgment entry filed February 25, 2022, the trial court

sentenced Legha to 210 days in jail, 208 days suspended, issued two days of jail time

credit, and ordered two years of nonreporting probation.

{¶ 5} On February 6, 2024, Legha filed a motion for leave to file a motion for new

trial based on newly discovered evidence. In an attached affidavit dated November 16,

2023, Legha claimed during a marriage counseling session, his wife admitted she Fairfield County, Case No. 24-CA-08 3

fabricated the allegations against him. By entry filed February 21, 2024, the trial court

denied the motion.

{¶ 6} Legha filed an appeal with the following assignment of error:

I

{¶ 7} "THE TRIAL COURT ERRED WHEN IT DID NOT ALLOW A HEARING ON

DEFENDANT-APPELLANT'S MOTION FOR A NEW TRIAL AND CAUSED A MANIFEST

INJUSTICE FOR THE DEFENDANT-APPELLANT."

{¶ 8} In his sole assignment of error, Legha claims the trial court erred in denying

his motion without holding a hearing. We disagree.

{¶ 9} A trial court's decision on a motion for leave to file a motion for new trial

rests in the trial court's sound discretion. State v. Williams, 43 Ohio St.2d 88 (1975),

paragraph two of the syllabus. A trial court's decision on whether to hold a hearing on

the motion is also reviewed under an abuse of discretion standard. State v. Sutton, 2016-

Ohio-7612, ¶ 24 (8th Dist.). "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 Enterprises, Inc. v.

River Place Community Urban Redevelopment Corp., 50 Ohio St.3d 157, 161 (1990). An

unreasonable decision is one backed by no sound reasoning process which 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. Fairfield County, Case No. 24-CA-08 4

{¶ 10} In his motion, Legha argued "newly discovered evidence" under Crim.R.

33(A)(6). Crim.R. 33(B) states in part:

Motions for new trial on account of newly discovered evidence shall

be filed within one hundred twenty days after the day upon which the verdict

was rendered, or the decision of the court where trial by jury has been

waived. If it is made to appear by clear and convincing proof that the

defendant was unavoidably prevented from the discovery of the evidence

upon which he must rely, such motion shall be filed within seven days from

an order of the court finding that he was unavoidably prevented from

discovering the evidence within the one hundred twenty day period.

{¶ 11} Clear and convincing evidence is that evidence "which will provide in the

mind of the trier of facts a firm belief or conviction as to the facts sought to be

established." Cross v. Ledford, 161 Ohio St. 469 (1954), paragraph three of the syllabus.

{¶ 12} In addition to showing an unavoidable delay in discovering the evidence, a

petitioner must also show that they filed their motion for leave within a reasonable time

after discovering the evidence. State v. Gray, 2010-Ohio-11, ¶ 18 (8th Dist.). Whether a

delay is reasonable depends on the facts and circumstances surrounding the case and

whether the petitioner has an adequate explanation for the delay. Id.

{¶ 13} Further, as held by the Supreme Court of Ohio in State v. Petro, 148 Ohio

St. 505 (1947), syllabus: Fairfield County, Case No. 24-CA-08 5

To warrant the granting of a motion for a new trial in a criminal case,

based on the ground of newly discovered evidence, it must be shown that

the new evidence (1) discloses a strong probability that it will change the

result if a new trial is granted, (2) has been discovered since the trial, (3) is

such as could not in the exercise of due diligence have been discovered

before the trial, (4) is material to the issues, (5) is not merely cumulative to

former evidence, and (6) does not merely impeach or contradict the former

evidence.

{¶ 14} In denying Legha's motion, the trial court determined the motion was

untimely as it was filed almost two years after the trial court's decision, well over 120 days.

See Entry filed February 21, 2024. In analyzing whether there was an unavoidable delay

in discovering the evidence, the trial court found, by clear and convincing evidence, that

Legha failed to meet his burden of establishing that "the alleged new evidence was

undiscoverable by reasonable diligence within one hundred twenty (120) days, or that he

was unavoidably prevented from filing a timely motion for a new trial." The trial court

found the wife's "recantation" was not newly discovered evidence; during the bench trial,

she recanted her statements made to law enforcement at the time of the incident. The

trial court noted Legha cross-examined his wife on her inconsistent statements; Legha

was well aware of this evidence before and during the trial. The trial court concluded

Legha did not have any new evidence to present. We agree with the trial court's analysis.

{¶ 15} In support of his motion, Legha submitted his own affidavit where he stated

he and his wife attended marriage counseling sessions.

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Related

State v. Petro
76 N.E.2d 370 (Ohio Supreme Court, 1947)
State v. Williams
330 N.E.2d 891 (Ohio Supreme Court, 1975)
Huffman v. Hair Surgeon, Inc.
482 N.E.2d 1248 (Ohio Supreme Court, 1985)

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Bluebook (online)
2024 Ohio 3431, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-legha-ohioctapp-2024.