State v. Mitchell

2025 Ohio 809
CourtOhio Court of Appeals
DecidedMarch 10, 2025
Docket2024-P-0047 & 2024-P-0051
StatusPublished

This text of 2025 Ohio 809 (State v. Mitchell) 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. Mitchell, 2025 Ohio 809 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Mitchell, 2025-Ohio-809.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT PORTAGE COUNTY

STATE OF OHIO, CASE NOS. 2024-P-0047 2024-P-0051 Plaintiff-Appellee,

-v- Criminal Appeals from the Court of Common Pleas JAMES E. MITCHELL,

Defendant-Appellant. Trial Court No. 1993 CR 00294

OPINION

Decided: March 10, 2025 Judgment: Affirmed

Connie J. Lewandowski, Portage County Prosecutor, and Kristina K. Reilly, Assistant Prosecutor, 241 South Chestnut Street, Ravenna, OH 44266 (For Plaintiff-Appellee).

James E. Mitchell, pro se, PID# A293-032, Marion Correctional Institution, 940 Marion- Williamsport Road, P.O. Box 57, Marion, OH 43301 (Defendant-Appellant).

SCOTT LYNCH, J.

{¶1} Defendant-appellant, James E. Mitchell, appeals from the judgments of the

Portage County Court of Common Pleas, denying his motions to dismiss and for a final

order. For the following reasons, we affirm the judgments of the lower court.

{¶2} In October 1993, the Portage County Grand Jury indicted Mitchell for Rape,

which was an aggravated felony of the first degree, in violation of R.C. 2907.02(A)(2), and

Aggravated Burglary, which was an aggravated felony of the first degree, in violation of

R.C. 2911.11(A)(1) and (3). In February 1994, Mitchell entered pleas of guilty to Gross

Sexual Imposition, a felony of the third degree, in violation of R.C. 2907.05(A)(4), and Burglary, a felony of the second degree, in violation of R.C. 2911.12(A)(1). The court

accepted the guilty pleas.

{¶3} Prior to sentencing, Mitchell filed a Motion to Withdraw Plea, which the trial

court denied. In June 1994, the court sentenced Mitchell to concurrent prison terms of

three to 15 years for Burglary and two years for Gross Sexual Imposition. Mitchell

appealed, arguing error in the denial of his Motion to Withdraw Plea. This court affirmed.

State v. Mitchell, 1995 WL 411830 (11th Dist. June 23, 1995).

{¶4} Mitchell filed several postconviction motions in 2016 and 2017, raising

various arguments including requests for appointed counsel and to withdraw his plea.

The trial court denied the motions and its judgments were affirmed on appeal. State v.

Mitchell, 2017-Ohio-8440 (11th Dist.).

{¶5} In 2018, Mitchell filed a Motion to Dismiss the indictment, which the trial

court denied. On appeal, this court rejected his argument alleging a violation of his right

to a speedy trial. State v. Mitchell, 2019-Ohio-844 (11th Dist.).

{¶6} In 2019, Mitchell filed motions requesting a final order and a corrected

sentencing entry. Mitchell argued that a final order was not issued since charges in the

indictment remained unresolved. This court held that the doctrines of res judicata and

the law of the case barred consideration of this issue. State v. Mitchell, 2020-Ohio-3417,

¶ 71-72 (11th Dist.). We also ordered, however, that the lower court issue nunc pro tunc

entries to correct clerical errors relating to the improper reference to an amended

indictment, incorrect statute number, and failure to state the fact of conviction in the

sentencing entry. Id. at ¶ 90-91. The court issued such entries in January 2021.

{¶7} Mitchell filed a Motion to Vacate Void Judgment of Conviction in 2021,

Case Nos. 2024-P-0047, 2024-P-0051 arguing that the court lacked subject matter jurisdiction in relation to his Gross Sexual

Imposition conviction. This court affirmed. State v. Mitchell, 2022-Ohio-1009 (11th Dist.).

{¶8} On October 17, 2023, Mitchell filed a Motion for a Final Appealable Order,

again arguing that a final order could not have been issued since charges against him

remained pending. On December 8, 2023, Mitchell filed a Motion to Dismiss Indictment,

arguing there was a violation of his right to a speedy trial due to pending charges. On

July 18, 2024, the trial court denied these motions.

{¶9} Mitchell timely appeals and raises the following assignments of error:

{¶10} “[1.] The trial court erred [by] denying Appellant’s Motion for a Final

Appealable Order.”

{¶11} “[2.] The refusal of the trial court to issue a final appealable order is denying

the Appellant the right to appeal his conviction and sentence.”

{¶12} “[3.] The refusal of the trial court to dismiss pending indicted charges

violates Appellant’s speedy trial rights.”

{¶13} We will address Mitchell’s first and second assignments of error jointly since

they both relate to the finality of the trial court’s judgment. In his first assignment of error,

Mitchell argues that there is no final judgment resolving the indicted charges of Rape and

Aggravated Burglary. He contends that since he pled guilty to charges not in the

indictment, i.e., Gross Sexual Imposition and Burglary, the Rape and Aggravated Burglary

charges were never resolved. In his second assignment of error, he argues that the lack

of a final order prevented him from appealing his convictions. The State contends these

arguments are barred by the doctrines of res judicata and the law of the case. We agree.

{¶14} “Res judicata bars the assertion of claims against a valid, final judgment of

Case Nos. 2024-P-0047, 2024-P-0051 conviction that have been raised or could have been raised on appeal.” State v. Ketterer,

2010-Ohio-3831, ¶ 59. Moreover, “‘[p]rinciples of res judicata prevent relief on

successive, similar motions raising issues which were or could have been raised

originally.’” (Citation omitted.) State v. Hall, 2011-Ohio-656, ¶ 7 (11th Dist.); also State

v. Bene, 2020-Ohio-1560, ¶ 14 (11th Dist.) (“[r]es judicata [bars] piecemeal claims in

successive postconviction relief petitions . . . that could have been raised, but were not,

in the first postconviction relief petition”) (citation omitted).

{¶15} The law of the case doctrine provides that “the decision of a reviewing court

in a case remains the law of that case on the legal questions involved for all subsequent

proceedings in the case at both the trial and reviewing levels.” Nolan v. Nolan, 11 Ohio

St.3d 1, 3 (1984). This rule “is necessary to ensure the consistency of results in a case,

to avoid endless litigation by settling the issues, and to preserve the structure of superior

and inferior courts as designed by the Ohio Constitution.” Id.

{¶16} Initially, although Mitchell argues that he was denied the right to appeal his

convictions due to the lack of a final order, this is inaccurate. He has pursued numerous

appeals and original actions before this court, all stemming from the same convictions.

Mitchell has had more than adequate opportunity to seek relief from this court, as

evidenced by the proceedings outlined above.

{¶17} Mitchell could have raised the arguments advanced here on direct appeal

and has in fact raised them in subsequent appeals, necessitating application of the

doctrine of res judicata. He has already advanced the arguments that the charges of

Rape and Aggravated Burglary were not disposed of in a final entry in prior appeals in

this court. “This court has emphasized that a defendant cannot use motions to reiterate

Case Nos. 2024-P-0047, 2024-P-0051 the same points and obtain additional opportunities to appeal.” State v. Feathers, 2024-

Ohio-5373, ¶ 11 (11th Dist.), citing State v. Sands, 2021-Ohio-659, ¶ 14 (11th Dist.)

(“Sands has repeatedly filed motion after motion in order to obtain final orders from which

he can appeal . . . .

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Related

State v. Ketterer
2010 Ohio 3831 (Ohio Supreme Court, 2010)
State v. Mitchell
2017 Ohio 8440 (Ohio Court of Appeals, 2017)
State v. Mitchell
2019 Ohio 844 (Ohio Court of Appeals, 2019)
State v. Bene
2020 Ohio 1560 (Ohio Court of Appeals, 2020)
State v. Mitchell
2020 Ohio 3417 (Ohio Court of Appeals, 2020)
State v. Sands
2021 Ohio 659 (Ohio Court of Appeals, 2021)
State v. Mitchell
2022 Ohio 1009 (Ohio Court of Appeals, 2022)
Nolan v. Nolan
462 N.E.2d 410 (Ohio Supreme Court, 1984)
State v. Tenney
2024 Ohio 5268 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 809, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mitchell-ohioctapp-2025.