State v. McFarland

2025 Ohio 1816
CourtOhio Court of Appeals
DecidedMay 15, 2025
Docket23CA13 & 23CA14
StatusPublished

This text of 2025 Ohio 1816 (State v. McFarland) 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. McFarland, 2025 Ohio 1816 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. McFarland, 2025-Ohio-1816.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT HOCKING COUNTY

State of Ohio, : : Plaintiff-Appellee, : Case Nos. 23CA13 : 23CA14 v. : : DECISION AND William A. McFarland, : JUDGMENT ENTRY : and : : Bobbi Jo McFarland, : : Defendants-Appellants. : _____________________________________________________________ APPEARANCES:

Donald K. Pond, Uniontown, Ohio, for Appellant, William McFarland.

Angela Miller, Jupiter, Florida, for Appellant, Bobbi Jo McFarland.

Jennifer M. Graham, Hocking County Prosecuting Attorney, Robert N. Abdalla and Elizabeth N. Bull, Hocking County Assistant Prosecuting Attorneys, Logan, Ohio, for Appellee. _____________________________________________________________

Smith, P.J.

{¶1} Appellants, William and Bobbi Jo McFarland, have both filed appeals

from their joint convictions for two counts of failure to provide for a functionally

impaired person, fourth-degree felonies in violation of R.C. 2903.16(A)(C)(1), as

well as their joint convictions for two counts of attempted failure to provide for a Hocking App. Nos. 23CA13 and 23CA14 2

functionally impaired person, fifth-degree felonies in violation of R.C.

2903.16(A)(C)(1). These matters were consolidated below and share the same trial

court record. Therefore, they have been sua sponte consolidated on appeal. On

appeal, Appellants both challenge the trial court’s imposition of consecutive

sentences. After review, we find the consecutive sentences imposed by the trial

court are contrary to law and are not supported by the record. Accordingly, the

judgments of the trial court are reversed, Appellants’ sentences are vacated, and

these matters are hereby remanded to the trial court for resentencing.

FACTS AND PROCEDURAL HISTORY

{¶2} On August 26, 2022, Appellants were each indicted on one count of

involuntary manslaughter, a first-degree felony in violation of R.C. 2903.04(A)

and (C), and one count of failing to provide for a functionally impaired person, a

fourth-degree felony in violation of R.C. 2903.16(C)(1). The functionally

impaired person named in the indictment was Joshua McFarland, who was the

adult son of William and the stepson of Bobbi Jo. The filing of the indictment

stemmed from Joshua’s death.

{¶3} The police report that was created at the time of the offense explained

that Joshua was transported to Fairfield Medical Center by his step-mother, Bobbi

Jo McFarland, on Saturday, April 23, 2022.1 Joshua was found to be “extremely

1 The police report was admitted as a joint exhibit during the change-of-plea hearing. Hocking App. Nos. 23CA13 and 23CA14 3

malnourished, had bruises and sores (some severe all the way to the bone)” and

died at the hospital. Per the report, “[i]t was suspected Joshua had not been taking

[sic] care of for some time.” The report stated that Bobbi Jo reported that Joshua

lived at home with her and her husband, William, and that Joshua hadn’t eaten or

drank for two days. The report further stated that Joshua had suffered with bed

sores for as long as six months, which had “gotten out of control.” Bobbi Jo also

reported that Joshua had not seen a physician for several years.

{¶4} The only information in the police report regarding Joshua’s medical

condition was that Joshua was “a thirty (30) year old, who was MRDD (Mental

Retardation and Developmental delay/disabilities).” The next day, the couple’s

three other minor children were removed from their care and both William and

Bobbi Jo were arrested and were subsequently indicted. The trial court set bond

for each of them at “$100,000 recognizance” or “$500,000 cash or surety.” Unable

to secure bond, both Appellants remained in jail for approximately six months.

{¶5} The cases were eventually consolidated, although each Appellant had

separate appointed counsel. Upon the motion of their defense counsel, the trial

court approved and advanced funds for the hiring of an expert. The trial court also

lowered the bond to a “$300,000 appearance bond.” Appellants, however,

remained in jail. Hocking App. Nos. 23CA13 and 23CA14 4

{¶6} Once the expert report was obtained, defense counsel moved the court

a second time for a reduction in bond. A bond hearing was thereafter held on

February 23, 2023. Excerpts of the expert report were read into the record as

follows: “ ‘[Joshua] had significant underlying comorbid diagnoses including

spastic quadriplegic cerebral palsy, malnutrition, liticachia (ph) and muscle

wasting, spastic dysphagia,’ and a bunch of other serious disorders which

contributed in large part to his death.” Another excerpt from the report read into

the record stated that Joshua had “surpassed the median life expectancy given the

severity of his disease and he would not have been predicted to live past 30 years.”

It was then noted that Joshua was “30 years and 7 months at the time of his death.”

The following opinion of the expert was read into the record as follows:

It’s my medical opinion that multiple external factors as those inherent to Mr. McFarland’s * * * natural disease process were outside the control and responsibility of his parents or caretakers. It is without a doubt that Joshua McFarland, the decedent, and his family were set up for failure.

The expert report was not admitted into evidence as an exhibit, nor was it

subsequently made part of the trial court record.

{¶7} Thereafter, and over the objection of the State, the trial court reduced

Bobbi Jo’s bond to “$25,000 with 10 percent permitted for cash or surety.” It

reduced William’s bond to “$50,000 with 10 percent permitted for cash or surety.”

Appellants were required to wear ankle monitors, confined to Hocking county, Hocking App. Nos. 23CA13 and 23CA14 5

were not allowed contact with each other, and there was no provision for visitation

with their other children. In agreeing to reduce the bond, and as will be explained

in more detail below, the trial court found that there was no great risk of danger to

others.

{¶8} The parties subsequently entered into plea negotiations, whereby

Appellants agreed to enter Alford pleas to reduced charges brought through a bill

of information in exchange for the dismissal of the original indictment. As a

result, both Appellants entered Alford pleas to two counts of failure to provide for

a functionally impaired person, fourth-degree felonies in violation of R.C.

2903.16(A)(C)(1), as well as two counts of attempted failure to provide for a

functionally impaired person, fifth-degree felonies in violation of R.C.

2903.16(A)(C)(1). The agreement provided that Appellants’ new reduced charges

would not be merged, but that Appellants would argue for community control

while the State would argue for maximum and consecutive sentences. The trial

court ordered presentence investigation reports be prepared ahead of sentencing.

{¶9} A sentencing hearing was held on August 23, 2023. Defense counsel

argued for community control, again citing to the expert report but failing to admit

the report into evidence. The State again recommended maximum and consecutive

sentences be imposed. The trial court ultimately sentenced both Appellants to

maximum prison terms of 18 months on each fourth-degree felony and maximum Hocking App. Nos. 23CA13 and 23CA14 6

prison terms of 12 months on each fifth-degree felony. The trial court further

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1816, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mcfarland-ohioctapp-2025.