State v. Moser

2025 Ohio 4422
CourtOhio Court of Appeals
DecidedSeptember 22, 2025
Docket2025-P-0002
StatusPublished

This text of 2025 Ohio 4422 (State v. Moser) 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. Moser, 2025 Ohio 4422 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Moser, 2025-Ohio-4422.]

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

STATE OF OHIO, CASE NO. 2025-P-0002 CITY OF KENT,

Plaintiff-Appellee, Criminal Appeal from the Municipal Court, Kent Division - vs -

RANDALL WILLIAM MOSER, Trial Court No. 2024 CRB 00908 K

Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: September 22, 2025 Judgment: Affirmed

Connie J. Lewandowski, Portage County Prosecutor, and Theresa M. Scahill, Assistant Prosecutor, 241 South Chestnut Street, Ravenna, OH 44266 (For Plaintiff-Appellee).

Alisa Boles, A.E. Boles, L.L.C., 35 East 202nd Street, Euclid, OH 44123 (For Defendant- Appellant).

EUGENE A. LUCCI, J.

{¶1} Appellant, Randall William Moser, appeals the judgment imposing sentence

following a bench trial wherein the trial court found him guilty of criminal damaging. We

affirm.

{¶2} On August 22, 2024, complaints were filed in the trial court charging Moser

with criminal damaging or endangering, a second-degree misdemeanor, in violation of

R.C. 2909.06(A)(1); and disorderly conduct by intoxication, a fourth-degree

misdemeanor, in violation of R.C. 2917.11(B)(2). {¶3} Moser pleaded not guilty. Thereafter, the case was scheduled for bench

trial. On the morning of trial, defense counsel orally moved for a continuance to allow the

defense to file a jury demand. The trial court denied the motion.

{¶4} Prior to commencing trial, the prosecutor informed the court that it would

not be pursuing the disorderly conduct charge. Following trial, the court found Moser guilty

of criminal damaging and set the matter for sentencing. In an entry dated December 30,

2024, the trial court sentenced Moser to 90 days in jail, with the jail sentence suspended

upon certain conditions.

{¶5} Moser appeals the judgment, assigning four errors for our review.

{¶6} In his first assigned error, Moser maintains:

{¶7} “The trial court erred when it denied a criminal defendant’s request for a trial

by jury on the basis that it was untimely without ascertaining the date he received notice

of the trial date.”

{¶8} Civ.R. 23(A) provides, in relevant part:

In petty offense cases, where there is a right of jury trial, the defendant shall be tried by the court unless he demands a jury trial. Such demand must be in writing and filed with the clerk of court not less than ten days prior to the date set for trial, or on or before the third day following receipt of notice of the date set for trial, whichever is later. Failure to demand a jury trial as provided in this subdivision is a complete waiver of the right thereto.

{¶9} Here, just prior to the commencement of trial, defense counsel orally moved

for a continuance to allow counsel to file a jury demand and have a jury trial set. Defense

counsel indicated that Moser had informed him that morning that he wished to have a jury

trial. Defense counsel stated that the demand would be “within the 10-day period,” but

made no reference as to when notice of the bench trial was received. Defense counsel

PAGE 2 OF 14

Case No. 2025-P-0002 stated, “we would ask for a continuance and allow me the opportunity to file a jury demand

for him and to have a jury trial set.” The State responded that it would not ordinarily object,

but it had subpoenaed a witness who was required to take time off work to attend trial

that day, and Moser did not file a timely written demand for a jury trial. The trial court

denied the motion, and the case proceeded to bench trial.

{¶10} Moser maintains that the trial court erred in denying the motion without

ascertaining when Moser received notice of the bench trial, relying on State v. Pulsifer,

1993 WL 130112 (11th Dist. Mar. 26, 1993). However, the circumstances in the present

case are distinguishable from those in Pulsifer. In that case, the defendant filed a jury

demand on June 29, 1992, which the trial court overruled the next day, holding that the

demand was filed less than ten days prior to the scheduled trial of July 2, 1992. Id. at *1.

In applying Crim.R. 23(A), the trial court also relied on June 17, 1992, as the date the

notice was sent pursuant to a notice that “was not time stamped and, therefore, not an

official part of the court’s journal,” instead of relying on the evidence presented by the

defendant that his trial counsel, “did not receive notification of the trial date until June 25,

1992.” Pulsifer at *1. Defense counsel indicated that, upon receipt of the trial notice, he

“immediately prepared a jury demand which was filed and time stamped on the next

Monday.” Id. Thus, on appeal, this court determined that the record supported that the

jury demand was timely filed pursuant to Crim.R. 23(A), as it was filed within three days

of the receipt of the notice of the trial date. Pulsifer at *1; see Crim.R. 45(A) (“When the

period of time prescribed or allowed is less than seven days, intermediate Saturdays,

Sundays, and legal holidays shall be excluded in computation.”).

PAGE 3 OF 14

Case No. 2025-P-0002 {¶11} Here, unlike Pulsifer, defense counsel did not file a written demand for a

jury trial, and counsel made no argument that a jury demand could still be timely filed

under the Criminal Rules based on the date of receipt of the notice. To the contrary,

defense counsel’s argument in support of the continuance implicitly acknowledged that a

continuance of the trial was necessary for a demand to be timely filed. Further, Crim.R.

23(A)’s written demand requirement serves important administrative purposes—it allows

courts to schedule jury trials appropriately and ensures defendants make deliberate

choices about trial format. Allowing last-minute oral requests would undermine these

purposes.

{¶12} Accordingly, Moser did not comply with the requirements of Civ.R. 23(A),

nor did he advance an argument that time remained for him to still comply when he orally

moved for a continuance on the morning of the bench trial.

{¶13} Therefore, Moser’s first assigned error lacks merit.

{¶14} In his second and third assigned errors, Moser argues:

2. The trial court erred in denying defendant’s Rule 29 motion because the prosecutor did not provide sufficient evidence that Appellant knowingly damaged a vehicle while throwing railroad track ballast in order to escape from an assai[l]ant.

3. The trial court erred in convicting Appellant of criminal damaging because overlooking his assertions that he was in fear of his life while retreating from a dangerous individual who had just assaulted him went against the manifest weight of the evidence.

{¶15} The question of whether sufficient evidence supports a conviction “is a test

of adequacy,” which we review de novo. State v. Thompkins, 1997-Ohio-52, ¶ 23. “In a

sufficiency-of-the-evidence inquiry, the question is whether the evidence presented, when

viewed in a light most favorable to the prosecution, would allow any rational trier of fact

PAGE 4 OF 14

Case No. 2025-P-0002 to find the essential elements of the crime beyond a reasonable doubt.” State v. Dent,

2020-Ohio-6670, ¶ 15, citing State v. Jenks, 61 Ohio St.3d 259 (1991), paragraph two of

the syllabus.

{¶16} Unlike the standard for the sufficiency of the evidence, the “[w]eight of the

evidence concerns ‘the inclination of the greater amount of credible evidence . . . to

support one side of the issue rather than the other.’” (Emphasis in original.) Thompkins

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Bluebook (online)
2025 Ohio 4422, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-moser-ohioctapp-2025.