State v. Lenard

2024 Ohio 5008, 256 N.E.3d 261
CourtOhio Court of Appeals
DecidedOctober 17, 2024
Docket113878
StatusPublished

This text of 2024 Ohio 5008 (State v. Lenard) 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. Lenard, 2024 Ohio 5008, 256 N.E.3d 261 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Lenard, 2024-Ohio-5008.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 113878 v. :

RICHARD LENARD, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: October 17, 2024

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-05-463837-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Daniel T. Van, Assistant Prosecuting Attorney, for appellee.

Richard Lenard, pro se.

LISA B. FORBES, J.:

Richard Lenard (“Lenard”), acting pro se, appeals from the trial

court’s journal entry denying his “motion to vacate void abinitio forfeiture orders for

lack of subject matter jurisdiction.” After reviewing the facts of the case and

pertinent law, we affirm the trial court’s judgment. I. Facts and Procedural History

In December 2005, Lenard pled guilty to various felony offenses

related to a “criminal scheme of fraud involving real property” and agreed to the

forfeiture of firearms, ammunition, and “items to be determined by the prosecutor’s

office” that were seized by the authorities in conjunction with this case. State v.

Lenard, 2013-Ohio-1995, ¶ 2 (8th Dist.) (“Lenard III”); Dec. 7, 2005 journal entry

memorializing plea agreement. On March 16, 2006, the court sentenced Lenard to

four years in prison and ordered that this sentence run consecutive to Lenard’s 11-

month prison sentence in State v. Lenard, Cuyahoga C.P. No. CR-05-468589-A.

On March 20, 2006, the court ordered that “$66,295.89 shall be paid

in restitution out of funds currently held by the State of Ohio and/or Shaker Heights

Police Department . . . .” On April 28, 2006, the court journalized an entry of

“forfeiture of seized contraband” in this case, detailing the additional items to be

forfeited, including two firearms, $162, and various electronic items such as

speakers, a large-screen television, and computer equipment.

Lenard did not file a direct appeal of his guilty plea, his sentence, the

restitution order, or the forfeiture order.

In 2007, Lenard was granted judicial release, and the court placed

him on five years of community-control sanctions (“CCS”). Lenard violated his CCS,

and in May 2009, the court terminated his CCS and ordered him to serve the

remainder of his prison term. Lenard “has been unable to abide by the conditions

of his [CCS] or the laws of this state and has been convicted in several other cases.” Lenard III at ¶ 4. This “case then wound its way through a tortured appellate

history, spawning various appeals, writs, and attempts to correct [a sentencing]

error.” Lenard III at ¶ 1. The trial court corrected the sentencing error and this

court affirmed in Lenard III. For a detailed procedural history of this case, see State

v. Lenard, 2010-Ohio-81 (8th Dist.); State v. Lenard, 2011-Ohio-1571 (8th Dist.);

and Lenard III. Suffice it to say that Lenard remains incarcerated to this day.

In addition to Lenard’s appellate filings in this court, he filed

countless motions in the underlying criminal case in the trial court. As related to

the instant appeal, on March 6, 2024, Lenard filed a “motion to vacate void abinitio

forfeiture orders for lack of subject matter jurisdiction.” The court denied this

motion on April 9, 2024, and it is from this order that Lenard appeals raising two

assignments of error for our review:

I. The trial court acted without authority to subject appellant’s bank account $99, 162.00, guns, ammo & other items to forfeiture when the State failed to comply with the mandatory procedural requirements of R.C. 2933.43(C).

II. The trial court . . . lacks authority to order the disposition of forfeited contraband to pay restitution.

II. Law and Analysis

A. Pro Se Litigants

The Ohio Supreme Court has repeatedly held that “pro se litigants . . .

must follow the same procedures as litigants represented by counsel.” State ex rel.

Gessner v. Vore, 2009-Ohio-4150, ¶ 5. “It is well-established that pro se litigants

are presumed to have knowledge of the law and legal procedures and that they are held to the same standard as litigants who are represented by counsel.” Sabouri v.

Ohio Dept. of Job & Family Servs., 145 Ohio App.3d 651, 654 (10th Dist. 2001).

B. Forfeiture of Items as Part of Lenard’s Plea Agreement

In Lenard’s first assignment of error, he argues as follows: “The issue

presented before this court is whether the state has complied with the mandatory

procedural requirements of R.C. 2933.43(C), giving the trial court authority to

proceed with forfeiture in this instant case.” In Lenard’s second assignment of error,

he argues that the “trial court lacked authority to order the disposition of forfeited

contraband to pay restitution in this instant case due to the fact that the State failed

to confer jurisdiction to the trial court giving it authority to proceed in the forfeiture

of Appellant’s property.” Because these two assignments of error are interrelated,

we review them together.

In both of his assignments of error, Lenard challenges the jurisdiction

of the trial court. “[W]hen a specific action is within a court’s subject-matter

jurisdiction, any error in the exercise of that jurisdiction renders the court’s

judgment voidable, not void. . . . Generally, a voidable judgment may be set aside

only if successfully challenged on direct appeal.” State v. Harper, 2020-Ohio-2913,

¶ 26.

Former R.C. 2933.43(C), which was in effect at the time the items in

question were forfeited, was repealed in 2006. The statute stated that the

“prosecuting attorney . . . shall file a petition for forfeiture, to the seizing law

enforcement agency of the contraband seized . . . .” In State v. McGuire, 2006-Ohio- 1330, ¶ 24 (8th Dist.), this court held that when forfeiture is part of a criminal

defendant’s plea agreement, the prosecutor need not comply with R.C. 2933.43(C).

“It is clear from the record that the forfeiture of the seized money was a voluntary

forfeiture by McGuire as part of the plea agreement. Because the parties’ agreement

governed the forfeiture of McGuire’s property, adherence to the forfeiture

procedures laid out in R.C. 2933.43 was unnecessary.” Id.

In the case at hand, it is undisputed that the forfeiture of several items

was part of Lenard’s plea agreement. As stated earlier in this opinion, this was

memorialized in the December 2005 journal entry reflecting Lenard’s guilty plea.

Furthermore, our review of the transcript from Lenard’s plea hearing shows that the

prosecutor put the terms of the plea agreement on the record by stating in open

court, and in Lenard’s presence, the following:

Your Honor, as part of these plea arrangements in these two cases, the defendant has agreed to forfeit and/or use for restitution monies that were seized by the Shaker Heights Police Department, namely $85,091.60 from a Bank One account that defendant had, $12,046 the defendant had in another Bank One account, $2,079.52 that the defendant had in a . . . Parkview Federal [account].

Further, Your Honor, the defendant has agreed to forfeit guns and ammunition that were seized from his residence by the Shaker Heights Police Department on the 6th day of January 2005.

Upon review, we find that because former R.C.

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Related

State v. Ketterer
2010 Ohio 3831 (Ohio Supreme Court, 2010)
State ex rel. Gessner v. Vore
2009 Ohio 4150 (Ohio Supreme Court, 2009)
State v. Lenard
2013 Ohio 1995 (Ohio Court of Appeals, 2013)
State v. Varholic
2015 Ohio 20 (Ohio Court of Appeals, 2015)
Sabouri v. Ohio Department of Job & Family Services
763 N.E.2d 1238 (Ohio Court of Appeals, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 5008, 256 N.E.3d 261, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lenard-ohioctapp-2024.