State v. Leitwein

2020 Ohio 3698, 154 N.E.3d 1282
CourtOhio Court of Appeals
DecidedJuly 13, 2020
Docket2019CA00054
StatusPublished
Cited by1 cases

This text of 2020 Ohio 3698 (State v. Leitwein) 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. Leitwein, 2020 Ohio 3698, 154 N.E.3d 1282 (Ohio Ct. App. 2020).

Opinion

[Cite as State v. Leitwein, 2020-Ohio-3698.]

COURT OF APPEALS FAIRFIELD COUNTY, OHIO FIFTH APPELLATE DISTRICT

JUDGES: STATE OF OHIO : Hon. W. Scott Gwin, P.J. : Hon. Patricia A. Delaney, J. Plaintiff-Appellee : Hon. Craig R. Baldwin, J. : -vs- : : Case No. 2019CA00054 JACOB B. LEITWEIN : : Defendant-Appellant : OPINION

CHARACTER OF PROCEEDING: Criminal appeal from the Fairfield County Municipal Court, Case No. 19-TRC-11271

JUDGMENT: Affirmed

DATE OF JUDGMENT ENTRY: July 13, 2020

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

MITCHELL R. HARDEN JAMES L. DYE Assistant City Prosecutor P.O.Box 161 136 West Main Street Pickerington, OH 43147 Lancaster, OH 43130 [Cite as State v. Leitwein, 2020-Ohio-3698.]

Gwin, P.J.

{¶1} Defendant-appellant Joseph B. Leitwein [“Leitwein”] appeals the November

20, 2019 Judgment Entry of the Fairfield County Municipal Court that denied his

Administrative License Suspension Appeal [“ALS”].

Facts and Procedural History

{¶2} On Sunday October 27, 2019, at approximately 3:22 a.m. Leitwein was

arrested and charged with OVI, in violation of R.C. 4511.19(A)(1)(a), Driving in marked

lanes, in violation of R.C. 4511.33, and Left of center, in violation of R.C. 4511.25. The

state trooper requested that Leitwein submit to a chemical test. Leitwein refused to

submit to the chemical test. Therefore, Leitwein's driver license was placed under an

ALS for one-year with the ability to receive driving privileges after thirty days. The trooper

served Leitwein with a copy of the citation which summoned Leitwein to appear in the

Fairfield County Municipal Court for his initial appearance on November 5, 2019 at 8:00

a.m. A sworn copy of the BMV2255 was filed in the Fairfield County Municipal Court on

October 28, 2020. Additionally, Leitwein signed a copy of the BMV2255 acknowledging

that the trooper provided him a copy of the form.

{¶3} Leitwein orally appealed the ALS at his initial appearance on November 5,

2019. The trial court took the matter under advisement. Leitwein filed a written appeal

of the ALS on November 6, 2019.

{¶4} The trial court conducted a hearing on Leitwein’s ALS appeal on November

8, 2019. At the conclusion of the hearing, the trial court orally overruled the appeal and

upheld the ALS. (T. at 8). The trial court filed a Judgment Entry overruling the Leitwein’s

ALS appeal and upholding the ALS on November 20, 2019. Fairfield County, Case No. 2019CA00054 3

Assignment of Error

{¶5} Leitwein raises one Assignment of Error,

{¶6} “I. THE TRIAL COURT ERRED BY FAILING TO VACATE THE

ADMINISTRATIVE LICENSE SUSPENSION WHEN THE COURT FAILED TO COMPLY

WITH THE MANDATORY REQUIREMENT CONTAINED IN R.C. § 4511.192 THEREBY

VIOLATING APPELLANT'S DUE PROCESS RIGHTS.

Law and Analysis

{¶7} Leitwein submits that failure to provide an accused charged with a violation

of R.C. 4511.19 and placed under an ALS an initial appearance within five days of the

date that he was charged as required by R.C. 4511.192(D)(1)(a), mandates the

termination of that Administrative License Suspension.

1. STANDARD OF APPELLATE REVIEW.

{¶8} Leitwein’s argument centers on an issue of law, not the discretion of the trial

court. “‘When a court’s judgment is based on an erroneous interpretation of the law, an

abuse-of-discretion standard is not appropriate. See Swartzentruber v. Orrville Grace

Brethren Church, 163 Ohio App.3d 96, 2005-Ohio-4264, 836 N.E.2d 619, ¶ 6; Huntsman

v. Aultman Hosp., 5th Dist. No. 2006 CA 00331, 2008-Ohio-2554, 2008 WL 2572598, ¶

50.’ Med. Mut. of Ohio v. Schlotterer, 122 Ohio St.3d 181, 2009-Ohio-2496, 909 N.E.2d

1237, ¶ 13.” State v. Fugate, 117 Ohio St.3d 261, 2008-Ohio-856, 883 N.E.2d 440, ¶6.

Because the assignment of error involves the interpretation of a statute, which is a

question of law, we review the trial court’s decision de novo. Med. Mut. of Ohio v.

Schlotterer, 122 Ohio St.3d 181, 2009-Ohio-2496, 909 N.E.2d 1237, ¶ 13; Accord, State

v. Pariag, 137 Ohio St.3d 81, 2013-Ohio-4010, 998 N.E.2d 401, ¶ 9; Hurt v. Liberty Fairfield County, Case No. 2019CA00054 4

Township, Delaware County, OH, 5th Dist. Delaware No. 17 CAI 05 0031, 2017-Ohio-

7820, ¶ 31.

2. Issue for Appeal: Whether the failure to provide an accused charged with a

violation of R.C. 4511.19 and placed under an ALS an initial appearance within five days

of the date that he was charged as required by R.C. 4511.192(D)(1)(a), mandates the

2.1. The Administrative License Suspension - Background.

{¶9} A person who is arrested for OVI or physical control is deemed to have

given consent for chemical tests to determine alcohol content. R.C. 4511.191(A)(2). R.C.

4511.191 authorizes immediate “on-the-spot” suspensions of driving privileges at the time

of an OVI arrest. R.C. 4511.191(D). Acting “[o]n behalf of the registrar” of the bureau of

motor vehicles (“BMV”), an arresting officer is required to implement an administrative

license suspension as to a motorist who either (1) refuses, upon the officer’s request, to

submit to a chemical test to determine blood, breath or urine alcohol content, or (2) takes

the test, but “fails” it, i.e., registers a blood-,breath-or urine-alcohol content exceeding

statutory limits. Id. Duration of the ALS is established by R.C. 4511.191(E) and (F), and

ranges from ninety days (imposed upon a first offender who “fails” a chemical test) to five

years (imposed upon an arrestee who refuses testing, and has refused chemical testing

on three or more prior occasions in the preceding five years). See, State v. Gustafson, 76

Ohio St.3d 425, 440-441, 1996-Ohio-299, 668 N.E.2d 435.

{¶10} An ALS is civil in nature and remedial in purpose. Gustafson, 76 Ohio St.3d

425, 440, 1996-Ohio-299, 668 N.E.2d 435. Fairfield County, Case No. 2019CA00054 5

2.2. Appeal of the ALS.

{¶11} “It is well settled that the Due Process Clause applies to the suspension or

revocation of a driver’s license” State v. Hochhausler, 76 Ohio St.3d 455, 459, 668 N.E.2d

457(1996)(citations mitted). Since “the Due Process Clause applies to the suspension...of

a driver’s license,” procedural safeguards are necessary to prevent an erroneous

deprivation of an individual’s property interest in a driver’s license. Hochhausler, 76 Ohio

St.3d at 459, 668 N.E.2d 457 (1996). R.C. 4511.197(A) subjects an ALS to judicial

oversight and provides a licensee with a process to appeal an ALS. The initial

appearance upon the underlying OVI charge will be held within five days after the date of

the person’s arrest or the issuance of a citation to the person that led to the ALS. R.C.

4511.192(D) (1) (a); R.C. 4511.196(A). The person charged with an OVI “may appeal the

suspension at the person’s initial appearance on the charge resulting from the arrest or

within the period ending thirty days after the...initial appearance.” R.C. 4511.197(A).

{¶12} The scope of that appeal is limited to certain statutory questions. When a

person appeals an ALS pursuant to R.C.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Wilhite
2026 Ohio 859 (Ohio Court of Appeals, 2026)
Hazelwood Assn., Inc. v. Helfrich
2025 Ohio 2968 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2020 Ohio 3698, 154 N.E.3d 1282, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-leitwein-ohioctapp-2020.