State v. McElfresh

CourtOhio Court of Appeals
DecidedApril 27, 2026
Docket25 NO 0532
StatusPublished

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

Opinion

[Cite as State v. McElfresh, 2026-Ohio-1532.]

IN THE COURT OF APPEALS OF OHIO SEVENTH APPELLATE DISTRICT NOBLE COUNTY

STATE OF OHIO,

Plaintiff-Appellee,

v.

DANIEL T. McELFRESH,

Defendant-Appellant.

OPINION AND JUDGMENT ENTRY Case No. 25 NO 0532

Criminal Appeal from the Court of Common Pleas of Noble County, Ohio Case No. CR222-2080

BEFORE: Katelyn Dickey, Carol Ann Robb, Mark A. Hanni, Judges.

JUDGMENT: Affirmed.

Atty. Jordan C. Croucher, Noble County Prosecutor, for Plaintiff-Appellee and

Daniel T. McElfresh, Defendant-Appellant.

Dated: April 27, 2026 –2–

DICKEY, J.

{¶1} Pro se Appellant, Daniel T. McElfresh, appeals from the October 28, 2025 judgment of the Noble County Court of Common Pleas denying his “Motion Releasing of Personal Property (Money)” and “Motion for Contempt of Court and for Release of Property” following hearings. On appeal, Appellant argues the trial court abused its discretion in denying his motions. Finding no reversible error, we affirm.

FACTS AND PROCEDURAL HISTORY

{¶2} Appellant previously resided at the Noble County Jail and currently resides at the Chillicothe Correctional Institution. On August 8, 2022, Appellant was indicted by the Noble County Grand Jury on one count of aggravated possession of drugs (methamphetamine), a felony of the fifth degree in violation of R.C. 2925.11(A) and (C)(1)(a). {¶3} Appellant was appointed counsel and arraigned on January 20, 2023. Appellant and Appellee, the State of Ohio, notified the trial court that a negotiated plea agreement had been reached. Appellant entered a guilty plea to the charge as contained in the indictment. The court accepted Appellant’s guilty plea after finding it was made in a knowing, intelligent, and voluntary manner pursuant to Crim.R. 11. {¶4} On January 30, 2023, Appellant was sentenced to 11 months in prison, concurrent to an unrelated term of imprisonment, and ordered to pay court costs. Appellant was given two days of jail-time credit. The court notified Appellant that he may be subjected to post-release control for up to two years. {¶5} Thereafter, the State was contacted by defense counsel regarding the submission of a joint entry for the release of Appellant’s personal property (money) ($475) which was signed and submitted. See (4/4/2023 Entry Releasing Defendant’s Personal Property (Money)). Unbeknownst to the State at that time, an investigation into the matter revealed that the money was actually returned to Appellant well in advance of that entry. A copy of the detective’s report was submitted into evidence. See (State’s Exhibit A). {¶6} Nevertheless, on February 16, 2024, Appellant filed a pro se “Motion Releasing of Personal Property (Money)” claiming that his personal property (money) ($475) that was originally seized had not been returned to him at the Chillicothe

Case No. 25 NO 0532 –3–

Correctional Institution. On January 3, 2025, Appellant filed a pro se “Motion for Contempt of Court and for Release of Property” claiming that the Noble County Sheriff’s Office had not returned the money and should be held in contempt. On January 24, 2025, the State filed a response detailing the following: Appellant’s personal property (money) ($475) was in fact returned to him when it was placed in his commissary account at the Noble County Jail while he remained incarcerated; it was subsequently applied to outstanding jail fees when said funds were not expended by Appellant during his time in the Noble County Jail; and Appellant actually still owes the Noble County Jail $1,284.07. See (State’s Exhibits A-E). On February 18, 2025, Appellant filed a pro se reply. {¶7} Appellant was re-appointed counsel. On September 2, 2025, a hearing was held on Appellant’s “Motion Releasing of Personal Property (Money).” On October 28, 2025, a hearing was held on Appellant’s “Motion for Contempt of Court and for Release of Property.” Appellant was present for both hearings via TEAMS. Appellant acknowledged and admitted that the money at issue ($475) was in fact returned to him. Following the hearings, on October 28, 2025, the trial court denied Appellant’s motions. {¶8} Appellant filed this pro se appeal. On December 22, 2025, Appellant filed a brief raising one assignment of error. On February 2, 2026, the State filed a brief. On March 9, 2026, Appellant filed an “Affidavit of McElfresh’s Response to State of Ohio,” which this court received and considered.

ASSIGNMENT OF ERROR

JUDGE RIDDLE ABUSED HER DISCRETION, VIOLATING DUE PROCESS, CIV.R. 64, AND R.C. 5120.56, IN DENYING MCELFRESH’S “MOTION FOR CONTEMPT OF COURT AND RELEASE OF PROPERTY . . . ,” RESULTING IN PREJUDICE TO MCELFRESH.

{¶9} In his sole assignment of error, Appellant argues the trial court abused its discretion in denying his “Motion Releasing of Personal Property (Money)” and “Motion for Contempt of Court and for Release of Property.” {¶10} “We review a trial court’s contempt finding for abuse of discretion.” State v. Scott, 2025-Ohio-5453, ¶ 16 (7th Dist.), citing State ex rel. Celebrezze v. Gibbs, 60 Ohio

Case No. 25 NO 0532 –4–

St.3d 69, 75 (1991). An abuse of discretion occurs when a court exercises its judgment “in an unwarranted way, in regard to a matter over which it has discretionary authority.” Johnson v. Abdullah, 2021-Ohio-3304, ¶ 35.

Contempt proceedings can be either civil or criminal, although the proceedings themselves are sui generis. Brown v. Executive 200, Inc., 64 Ohio St.2d 250, 253, 416 N.E.2d 610 (1980). In civil contempt, the purpose of punishment is to coerce the contemnor to obey a judicial order for the benefit of a third party. Carroll v. Detty, 113 Ohio App.3d 708, 711, 681 N.E.2d 1383 (1996). In a civil contempt action the contemnor is said to “carry the keys of his prison in his own pocket . . . since he will be freed if he agrees to do as ordered.” Pugh v. Pugh, 15 Ohio St.3d 136, 139, 472 N.E.2d 1085 (1984), quoting Brown at 253, 416 N.E.2d 610. The burden of proof for the moving party in a civil contempt action is clear and convincing evidence. Carroll at 711, 681 N.E.2d 1383. Once the moving party establishes a prima facie case of contempt, the burden shifts to the nonmoving party to establish a defense. Morford v. Morford, 85 Ohio App.3d 50, 55, 619 N.E.2d 71 (1993). The nonmoving party must prove any defense by a preponderance of the evidence. Jeffers v. Jeffers, 7th Dist. No. 07 BE 36, 2008-Ohio-3339, at ¶ 15, 2008 WL 2609465.

Ferguson v. Boron, 2018-Ohio-69, ¶ 14 (7th Dist.).

{¶11} The record in this case does not support Appellant’s claim that his money ($475) was never returned to him. As stated, in its January 24, 2025 response to Appellant’s motions, the State detailed the following: Appellant’s personal property (money) ($475) was in fact returned to him when it was placed in his commissary account at the Noble County Jail while he remained incarcerated; it was subsequently applied to outstanding jail fees when said funds were not expended by Appellant during his time in the Noble County Jail; and Appellant actually still owes the Noble County Jail $1,284.07. See (State’s Exhibits A-E). {¶12} Specifically, Exhibit A, “Investigative Report” from Detective Captain Kelly McGilton, explains the following:

Case No. 25 NO 0532 –5–

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Related

Jeffers v. Jeffers, 07 Be 36 (6-24-2008)
2008 Ohio 3339 (Ohio Court of Appeals, 2008)
Morford v. Morford
619 N.E.2d 71 (Ohio Court of Appeals, 1993)
Carroll v. Detty
681 N.E.2d 1383 (Ohio Court of Appeals, 1996)
Ferguson v. Van Boron
2018 Ohio 69 (Ohio Court of Appeals, 2018)
Johnson v. Abdullah (Slip Opinion)
2021 Ohio 3304 (Ohio Supreme Court, 2021)
Brown v. Executive 200, Inc.
416 N.E.2d 610 (Ohio Supreme Court, 1980)
Pugh v. Pugh
472 N.E.2d 1085 (Ohio Supreme Court, 1984)
State v. Scott
2025 Ohio 5453 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
State v. McElfresh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mcelfresh-ohioctapp-2026.