State v. Livingston

2026 Ohio 1080
CourtOhio Court of Appeals
DecidedMarch 27, 2026
DocketWD-25-036
StatusPublished

This text of 2026 Ohio 1080 (State v. Livingston) 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. Livingston, 2026 Ohio 1080 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Livingston, 2026-Ohio-1080.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT WOOD COUNTY

State of Ohio Court of Appeals No. WD-25-036

Appellee Trial Court No. 24 CR 158

v.

Henry Livingston, III. DECISION AND JUDGMENT

Appellant Decided: March 27, 2026

*****

Paul A. Dobson, Wood County Prosecuting Attorney, and Kristofer Kristofferson, Assistant Prosecuting Attorney, for appellee.

Jeffrey Nunnari, for appellant.

***** SULEK, J.

{¶ 1} Appellant, Henry Livingston, III, appeals a judgment of the Wood County

Court of Common Pleas which, following his guilty plea to abduction, sentenced him to

30 months of imprisonment. Because no plain error occurred at sentencing, the judgment

is affirmed.

I. Facts and Procedural History

{¶ 2} The Wood County Grand Jury indicted Livingston on one count of

abduction, R.C. 2905.02(A)(2), (C), a third-degree felony, and rape, R.C. 2907.02(A)(2),

(B), a first-degree felony. The charges stemmed from an incident at a hotel in Perrysburg, Wood County, Ohio, where Livingston allegedly raped and prevented the

victim from leaving a hotel room.

{¶ 3} The parties subsequently reached a plea agreement whereby the State agreed

to dismiss the rape charge and Livingston would plead guilty to abduction. At the March

27, 2025 plea hearing, the parties added:

[DEFENSE COUNSEL]: It is, Judge and I don’t think that we put it in the plea forms, but I think that the State was remaining – agreeing to remain silent at sentencing as well. [PROSECUTOR]: It is not on the form, but Ms. Roller is correct that the State would be declining to make a sentence recommendation. THE COURT: All right, thank you. And, Mr. Livingston, did you hear the Prosecutor? THE DEFENDANT: Yes, sir. THE COURT: Is that your understanding of the agreement? THE DEFENDANT: Yes, Your Honor.

{¶ 4} At the sentencing hearing, after defense counsel and Livingston addressed

the court, the prosecutor stated:

[F]irst we would note, as the Court indicated, the victim was notified, she is not present. There are victim representatives, friends and family members that are present on her behalf. We would incorporate the victim impact statement into our sentencing here, ask the Court to consider that. We would note that under 2929.12, the seriousness factors the Court does need to consider, I think the statement does make clear the victim did suffer serious psychological harm that she is still dealing with to this day. Certainly, the offender’s relationship with the victim facilitated the offense in this case. And, regarding remorse, Your Honor, and whether the apology was genuine or not, we would just note that the Defendant did not participate in the presentence report, we think that reflects on his remorse. There was an explanation given about another court matter that was going on at the same time, but this is a serious felony sentencing for which the Defendant was given multiple opportunities to participate in that presentence investigation, and I think the report reflects the multiple attempts to get his participation that were not responded to or declined, so we do think that reflects on the recidivism factor and the remorse factor, so

2. we’re asking the Court to take those factors into account when it imposes its sentence today.

{¶ 5} Sentencing Livingston, the court stated that it considered “the seriousness

and recidivism factors both mentioned by the Prosecutor’s office and those as listed in

their entirety,” the principles and purposes of sentencing under R.C. 2929.11, the fact that

the conviction was for a violent offense, the presentence investigation report and victim

impact statement, and the need for “deterrence, incapacitation, rehabilitation and

restitution.” The court then imposed a 30-month imprisonment term; this appeal

followed.

II. Assignment of Error

{¶ 6} On appeal, Livingston raises the following assignment of error:

ASSIGNMENT OF ERROR: The State of Ohio breached its plea agreement with appellant by not remaining silent at sentencing.

III. Analysis

{¶ 7} In Livingston’s sole assignment of error he argues that the State breached

the plea agreement by failing to remain silent at sentencing. Livingston concedes that the

court’s review is limited to plain error because he failed to object.

{¶ 8} “Plain errors or defects affecting substantial rights may be noticed although

they were not brought to the attention of the court.” Crim.R. 52(B). Plain error will be

recognized only where an obvious error impacted the outcome of the proceedings. State

v. Roby, 2022-Ohio-223, ¶ 12 (6th Dist.), citing State v. Rogers, 2015-Ohio-2459, ¶ 22.

Recognition of plain error is discretionary with the reviewing court; it is not mandatory.

Id., citing Rogers at ¶ 22-23. Plain error should be noticed by the reviewing court “only

3. if the error seriously affects the fairness, integrity or public reputation of judicial

proceedings.” Id., citing State v. Barnes, 94 Ohio St.3d 21, 27 (2002).

{¶ 9} “Where a guilty plea ‘rests in any significant degree on a promise or

agreement of the prosecutor, so that it can be said to be part of the inducement or

consideration, such promise must be fulfilled.’” State v. Shell, 2020-Ohio-295, ¶ 10 (6th

Dist.), quoting State v. Ross, 2008-Ohio-5388, ¶ 12 (6th Dist.), citing Santobello v. New

York, 404 U.S. 257, 262 (1971). The prosecutor’s failure to keep that promise may entitle

the defendant to specific performance of the agreement or to withdraw his guilty plea.

Id., citing State v. Montgomery, 2008-Ohio-4753 (4th Dist.).

{¶ 10} We reject Livingston’s initial assertion that the agreement is ambiguous

because at the plea hearing his counsel represented that the State agreed to “remain

silent” at sentencing while the State indicated that it would “be declining to make a

sentence recommendation.” Livingston agreed that the prosecutor’s statement reflected

his understanding of the agreement.

{¶ 11} An agreement by the prosecution to take no position on the sentence does

not entirely foreclose the State’s participation in the sentencing hearing. Shell at ¶ 11,

citing State v. Ahlers, 2015-Ohio-131, ¶ 12-13 (6th Dist.). The State may “‘provide

relevant factual information or correct misstatements’ without running afoul of an

agreement,” id., quoting State v. Crump, 2005-Ohio-4451, ¶ 11 (3d Dist.), but is

“restricted ‘from attempting to influence the sentence by presenting the court with

conjecture, opinion, or disparaging information already in the court’s possession.’” Id.,

quoting Ahlers at ¶ 16, citing Ross at ¶ 14 and Crump at ¶ 11.

4. {¶ 12} Here, the prosecutor stated that under the seriousness sentencing factors,

the victim suffered serious harm, that Livingston’s relationship with the victim facilitated

the offense, and he questioned the genuineness of Livingston’s remorse based on his

failure to cooperate with the presentence investigation. The prosecutor then specifically

requested that the court consider the facts he presented in fashioning Livingston’s

sentence. On review, we agree that the statements violated the plea agreement because

they were presented in an attempt to influence the sentence.

{¶ 13} In addition to finding that the State breached the plea agreement, the court

must examine the impact of the error, if any.

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Related

Santobello v. New York
404 U.S. 257 (Supreme Court, 1971)
State v. Ahlers
2015 Ohio 131 (Ohio Court of Appeals, 2015)
State v. Montgomery, 07ca858 (9-15-2008)
2008 Ohio 4753 (Ohio Court of Appeals, 2008)
State v. Ross
900 N.E.2d 678 (Ohio Court of Appeals, 2008)
State v. Crump, Unpublished Decision (8-29-2005)
2005 Ohio 4451 (Ohio Court of Appeals, 2005)
State v. Shell
2020 Ohio 295 (Ohio Court of Appeals, 2020)
State v. Roby
2022 Ohio 223 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 1080, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-livingston-ohioctapp-2026.