State v. Meeks

2026 Ohio 80
CourtOhio Court of Appeals
DecidedJanuary 12, 2026
Docket16-24-12; 16-24-13
StatusPublished

This text of 2026 Ohio 80 (State v. Meeks) 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. Meeks, 2026 Ohio 80 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Meeks, 2026-Ohio-80.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT WYANDOT COUNTY

STATE OF OHIO, CASE NO. 16-24-12

PLAINTIFF-APPELLEE,

v.

MICHAEL DONNELL MEEKS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

STATE OF OHIO, CASE NO. 16-24-13

MICHAEL DONNELL MEEKS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

Appeals from Wyandot County Common Pleas Court Trial Court Nos. 23-CR-0027 and 23-CR-0031

Judgment Affirmed in App. No. 16-24-12 Judgment Affirmed in Part, Reversed in Part and Cause Remanded in App. No. 16-24-13

Date of Decision: January 12, 2026 Case Nos. 16-24-12, 13

APPEARANCES:

Erica J. Gordon for Appellant

Andrea K. Boyd for Appellee

ZIMMERMAN, P.J.

{¶1} Defendant-appellant, Michael Donnell Meeks (“Meeks”), appeals the

December 2, 2024 judgment entries of sentencing of the Wyandot County Court of

Common Pleas. For the reasons that follow, we affirm in part and reverse in part.

{¶2} On February 17, 2023, in Case No. 23-CR-0027, the Wyandot County

Grand Jury indicted Meeks on a single count of rape in violation of R.C.

2907.02(A)(2), a first-degree felony. The offense was alleged to have been

committed on February 5, 2023, to a 16-year-old victim.

{¶3} On March 8, 2023, in Case No. 23-CR-0031, the Wyandot County

Grand Jury indicted Meeks on nine counts of rape in violation of R.C.

2907.02(A)(2), all first-degree felonies. The offenses were alleged to have been

committed between June 7, 2017 and October 31, 2021, to an additional victim who

was 14 years old at the time of the first incident of rape.

{¶4} On March 16, 2023, Meeks appeared for arraignment and entered pleas

of not guilty in both cases.

{¶5} On March 24, 2023, the State filed a motion for joinder of the cases,

which the trial court granted on April 13, 2023.

-2- Case Nos. 16-24-12, 13

{¶6} The cases proceeded to a jury trial on October 1-3, 2024. On October

3, 2024, the jury found Meeks guilty of the single count of rape in Case No. 23-CR-

0027, and guilty of all nine counts of rape in Case No. 23-CR-0031.

{¶7} On November 15, 2024, in Case No. 23-CR-0027, the trial court

sentenced Meeks to a prison term of a minimum of nine years up to a maximum of

13.5 years, to run consecutively to the sentence in 23-CR-0031.1

{¶8} On that same day, in Case No. 23-CR-0031, the trial court sentenced

Meeks to a prison term on each of the nine counts of rape.2 Initially, the trial court

sentenced Meeks as follows:

It is the sentence of the law and the Judgment of this Court, that [Meeks] be sentenced as follows: Count One – to a prison term of a minimum of nine (9) years; Count Two – to a prison term of a minimum of eight (8) years; Count Three – to a prison term of a minimum of eight (8) years; Count Four – to a prison term of a minimum of eight (8) years; Count Five – to a prison term of a minimum of eight (8) years; Count Six – to a prison term of a minimum of eight (8) years; Count Seven – to a prison term of a minimum of eight (8) years; Count Eight – to a prison term of a minimum of eight (8) years; Count Nine – to a prison term of a minimum of eight (8) years; all counts shall be served consecutively to one another, and shall be served in the custody of the Director of the Ohio Department of Corrections and Rehabilitation. Therefore, the minimum term is seventy-three (73) years to a maximum term not to exceed seventy-seven and one-half (77.5) years. Further, this sentence shall run consecutive to the sentence in Case No. 23-CR- 0027.

The Court found Count One in Case No. 23-CR-0031 to be the most serious felony offense. The victim was fourteen (14) at the time,

1 The trial court filed its judgment entry of sentencing in Case No. 23-CR-0027 on December 2, 2024. 2 The trial court filed its judgment entry of sentencing in Case No. 23-CR-0031 on December 2, 2024.

-3- Case Nos. 16-24-12, 13

therefore, the maximum sentence will be determined by the most serious offense, which was Count One in Case No. 23-CR-0031, and [Meeks] is sentenced to a total minimum prison term of seventy-three (73) years to a maximum prison term of seventy-seven and one-half (77.5) years.

(Doc. No. 31). After being advised that the rape offense in Count One was

committed in 2017, the trial court sentenced Meeks as follows:

The Court came back on the record and noted that Counsel had approached the Court and pointed out that Count One of this case was committed in 2017, which was prior to the Reagan Tokes Act coming into effect. Therefore, the Re[a]gan Tokes Act is not retroactive to that offense and the Court cannot impose an indefinite prison sentence in that matter. [Meeks] is receiving the same sentence as previously imposed and the Court will impose a prison sentence of nine (9) years as to Count One; eight (8) years as to Count Two; eight (8) years as to Count Three; eight (8) years as to Count Four; eight (8) years as to Count Five; eight (8) years as to Count Six; eight (8) years as to Count Seven; eight (8) years as to Count Eight, and as to Count Nine – the Court makes a finding that Count Nine is the worst offense that was committed by [Meeks] and the most serious felony offense. The Court, in making that finding and reflecting back to the testimony presented at trial, finds [Meeks] physically assaulted the victim, tied her up to a chair and raped her. Therefore, the Court will use that to determine [Meeks’s] maximum sentence. Therefore, [Meeks’s] minimum prison sentence is seventy-three (73) years to a maximum of seventy-seven (77) years. Again, this case shall run consecutive to Case No. 23-CR-0027 for the reasons previously explained by the Court for Case No. 23-CR-0027.

(Id.).

{¶9} On December 20, 2024, Meeks filed a notice of appeal in both cases.3

He raises three assignments of error for our review.

3 For purposes of appeal, Case No. 23-CR-0027 is designated as App. No. 16-24-12, and Case No. 23-CR- 0031 is designated as App. No. 16-24-13.

-4- Case Nos. 16-24-12, 13

First Assignment of Error

The Trial Court Committed Prejudicial Error In Allowing The State Of Ohio To Recall A Witness For Identification Purposes Thus Allowing the State To Supplement The Witness’[s] Testimony After Failing To Have Her Identify The Defendant.

{¶10} In his first assignment of error, Meeks argues that the trial court abused

its discretion by allowing the State to recall a witness to give additional testimony.

In particular, Meeks asserts that “[t]he trial court should have denied the state’s

request to recall the witness for purposes of identification.” (Appellant’s Brief at

9).

Standard of Review

{¶11} Evid.R. 611(A) provides that “[t]he court shall exercise reasonable

control over the mode and order of interrogating witnesses and presenting of

evidence so as to (1) make the interrogation and presentation effective for the

ascertainment of the truth, (2) avoid needless consumption of time, and (3) protect

witnesses from harassment and undue embarrassment.”

{¶12} “Whether to permit a witness to be recalled to the stand to give

additional testimony is a matter committed to the sound discretion of the trial court.”

State v. Barry, 2013-Ohio-2380, ¶ 59 (3d Dist.). An abuse of discretion suggests

that the trial court’s decision is unreasonable, arbitrary, or unconscionable.

Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983).

-5- Case Nos. 16-24-12, 13

Analysis

{¶13} In this case, the State called A.K. to testify as its second witness on the

first day of trial. A.K.

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

Related

State v. Bonnell (Slip Opinion)
2014 Ohio 3177 (Ohio Supreme Court, 2014)
State v. Hunter
2011 Ohio 6524 (Ohio Supreme Court, 2011)
State v. Berry
2013 Ohio 2380 (Ohio Court of Appeals, 2013)
State v. Marcum (Slip Opinion)
2016 Ohio 1002 (Ohio Supreme Court, 2016)
State v. Martin
485 N.E.2d 717 (Ohio Court of Appeals, 1983)
State v. Nienberg
2017 Ohio 2920 (Ohio Court of Appeals, 2017)
State v. Mason
2020 Ohio 3505 (Ohio Court of Appeals, 2020)
State v. Dehass
227 N.E.2d 212 (Ohio Supreme Court, 1967)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
State v. Gwynne
2023 Ohio 3851 (Ohio Supreme Court, 2023)
State v. Rawlins
2024 Ohio 1733 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 80, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-meeks-ohioctapp-2026.