State v. Platt

2024 Ohio 1331
CourtOhio Court of Appeals
DecidedApril 2, 2024
Docket23CA9
StatusPublished
Cited by1 cases

This text of 2024 Ohio 1331 (State v. Platt) 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. Platt, 2024 Ohio 1331 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Platt, 2024-Ohio-1331.]

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

STATE OF OHIO, :

Plaintiff-Appellant, : CASE NO. 23CA9

v. :

DONALD PLATT, : DECISION AND JUDGMENT ENTRY

Defendant-Appellee. :

________________________________________________________________

APPEARANCES:

Keller J. Blackburn, Athens County Prosecuting Attorney, and Merry M. Saunders, Assistant Prosecuting Attorney, Athens, Ohio, for appellant.

Addison M. Spring, Assistant State Public Defender, Columbus, Ohio, for appellee1. ________________________________________________________________ CRIMINAL APPEAL FROM COMMON PLEAS COURT DATE JOURNALIZED:4-2-24 ABELE, J.

{¶1} This is an appeal from an Athens County Common Pleas

Court judgment that granted judicial release to Donald Platt,

defendant below and appellee herein. The State of Ohio,

plaintiff below and appellant herein, assigns one error for

review:

“THE TRIAL COURT ERRED WHEN IT GRANTED PLATT’S MOTION FOR JUDICIAL RELEASE WITHOUT ARTICULATING THE REQUISITE FACTORS

1 Different counsel represented appellant during the trial court proceedings. ATHENS, 23CA9 2

SUPPORTING ITS DECISION PURSUANT TO R.C. 2929.20(J).”

{¶2} On March 5, 2021, appellee’s 14-year-old son, M.P.,

removed a loaded weapon from an unlocked gun cabinet and

accidentally shot and killed 11-year-old E.S., a friend of

appellee’s 11-year-old son, L.P. See State v. Platt, 4th Dist.

Athens No. 22CA2, ____ Ohio ____. After a jury found appellee

guilty of involuntary manslaughter, in violation of R.C.

2903.04(A), a first-degree felony, and child endangering, in

violation of R.C. 2919.22(A), a third-degree felony, the trial

court (1) merged the endangering children offense with the

involuntary manslaughter offense, (2) sentenced appellee to

serve an indefinite four- to six-year prison term, (3) issued

the required Reagan Tokes Act notifications, and (4) ordered a

mandatory five-year post-release control term. This court

affirmed appellee’s convictions in Platt, supra.

{¶3} On December 8, 2022, appellee filed a motion for

judicial release, pursuant to R.C. 2929.20.2 At appellee’s

judicial release hearing, the trial court reviewed appellee’s

rehabilitative efforts while incarcerated, heard arguments from

2 Appellee applied for judicial release under the former version of R.C. 2929.20, effective March 22, 2019 to April 3, 2023. The latest version of R.C. 2929.20, effective October 3, 2023, and other versions in between, add, among other items, language regarding state of emergency-qualifying offenders, but otherwise is substantively the same regarding issues related to this appeal. ATHENS, 23CA9 3

the state and appellee’s counsel, and considered victim impact

statements from two of the victim’s sisters. In addition,

appellee testified that he felt “truly remorseful” and wanted to

“get out and be a better father.”

{¶4} The trial court stated on the record that appellee had

“been held accountable.” The court further noted that appellee

(1) is a “first-time felony offender,”(2) had “never [been] in

trouble previously,” (3) had “indications of drug use,” (4)

“never had a problem with the boys previously handling the

firearm,” and (5) the firearm “was removed without his knowledge

or permission.” The court noted that appellee taught the boys

gun safety and, although appellee may have left the cabinet

unlocked that day, he did not know that they knew the gun

cabinet’s combination.

{¶5} The trial court also found that appellee had two

“minor” violations on his institutional summary report, one “for

being out of place the other was for not reporting to work on

time.” The court further noted that certifications in the

record show that appellee “completed course work” while in

prison. For example, appellee participated in the

“transformational program, how to be a responsible father, how

to cage your rage one and two,” “the only person you cheat is

you,” and Bible study. Therefore, the court found that appellee

“made somewhat productive use of his time there as well as if I ATHENS, 23CA9 4

remember correctly working while he’s been there.”

{¶6} The trial court further found that appellee “has been

adequately punished” and “the chance of recidivism is low. He

is no longer legally allowed to proses [sic.] a firearm.” The

court concluded that the “factors reviewed” * * * [are]

“outweighed by his completion of programming while in prison”

and * * * his low security levels.” The court stated that

judicial release would:

protect the public from future criminal violations by the offender because the factors indicating a lesser likelihood of recidivism are present and outweigh the applicable factors indicating the greater likelihood of recidivism as well as B that a sanction other than prison here would be in addition to prison but not to demean the seriousness of the offense because the factors here indicating the eligible offenders conduct was less serious than conduct normally constituting the offense and outweighs the factors indicating that his conduct was more serious than conduct normally constituting the offense.

{¶7} Accordingly, the trial court granted judicial release.

The following facts are taken from the trial court’s May 4, 2023

entry:

The Court finds Defendant has served more than one year on his four to six year indeterminate sentence. The Court finds as a result that Defendant is eligible to apply for judicial release.

Pursuant to R.C. 2929.20 a court shall not grant a judicial release under this section to an eligible offender who is imprisoned for a felony of the first or second degree, or to an eligible offender who committed ATHENS, 23CA9 5

an offense under Chapter 2925 or 3719 of the Revised Code and for whom there was a presumption under section 2929.13 of the Revised Code in favor of a prison term, unless the court makes certain findings. See R.C. Section 2929.20(J)(1). After hearing from counsel, review of the record, after hearing from the victim’s family, after hearing from Defendant, the court finds with reference to factors under section 2929.12 of the Revised Code, including but not limited to, Defendant owed a duty of care to the victim visiting his residence, Defendant was remorseful for his actions (or lack of action in securing the cabinet lock), this was Defendant’s first felony offense, the victim was a minor visiting the residence and suffered a fatal single shot by the mishandling of a firearm by Defendant’s minor son, that the cabinet had a lock - that it was unlocked - and Defendant’s children knew the combination, that there was no animosity or ill will among any of those involved, that the victim’s family suffered a tragic loss, that the Defendant nor Defendant’s minor son did not expect to cause any physical harm to the victim, the offense was committed under circumstances unlikely to recur, and that the shooting itself by Defendant’s minor son was accidental.

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Bluebook (online)
2024 Ohio 1331, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-platt-ohioctapp-2024.