State v. Pruitt

2025 Ohio 1557
CourtOhio Court of Appeals
DecidedMay 1, 2025
Docket114417
StatusPublished

This text of 2025 Ohio 1557 (State v. Pruitt) 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. Pruitt, 2025 Ohio 1557 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Pruitt, 2025-Ohio-1557.]

COURT OF APPEALS OF OHIO

EIGHT APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 114417 v. :

DENVER PRUITT, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: May 1, 2025

Criminal Appeal from the Cuyahoga County Common Pleas Court Case No. CR-24-693239-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Christopher Woodworth, Assistant Prosecuting Attorney, for appellee.

Patrick S. Lavelle, for appellant.

ANITA LASTER MAYS, J.:

{¶1} Defendant-appellant Denver Pruitt (“Pruitt”) appeals his convictions

and sentence and asks this court to reverse the trial court’s finding of guilt and his

sentence. We affirm. {¶2} On July 4, 2024, Pruitt was charged with one count of felonious

assault, a second-degree felony, in violation of R.C. 2903.11(A)(2); one count of

improper discharging of a firearm at or into a habitation or school, a second-degree

felony, in violation of R.C. 2923.161(A)(1); one count of discharging a firearm at or

near a prohibited premises, a third-degree felony, in violation of

R.C. 2923.162(A)(3); one count of carrying a concealed weapon, a fourth-degree

weapon, in violation R.C. 2923.12(A)(2). One- and three-year firearm

specifications were attached to the felonious-assault charge.

{¶3} On September 3, 2024, after plea negotiations with the State, Pruitt

entered a guilty plea to an amended indictment. Pruitt pleaded guilty to one count

of felonious assault, a second-degree felony, in violation of R.C. 2903.11(A)(2),

with a one-year firearm specification. He also pleaded guilty to discharging a

firearm on or near prohibited premises, a third-degree felony, in violation of

R.C. 2923.162(A)(3). The remaining charges were dismissed by the State.

{¶4} On October 7, 2024, the trial court vacated Pruitt’s sentence due to a

clerical error on the September 30, 2024 sentencing entry. The trial court

sentenced Pruitt to seven years’ imprisonment, which included a mandatory one-

year imprisonment sentence on the firearm specification to be served

consecutively to six years’ imprisonment on the felony. Additionally, the trial court

imposed a possible additional sentence, in accordance with the Reagan Tokes Act,

where the department of rehabilitation and correction may make determinations and maintain Pruitt’s incarceration under R.C. 2967.271, which would add up to

three additional years of incarceration onto Pruitt’s sentence.

I. Facts and Procedural History

A. Plea Hearing

{¶5} On September 3, 2024, Pruitt pleaded guilty to amended indictment.

At the plea hearing, the trial court stated:

Before I can take guilty pleas from you, I need to give you information and get information from you with the aim of making sure that, if you do plead guilty this afternoon, your pleas are intelligently, you know what you’re admitting to and the possible sentences, voluntary, meaning you’re agreeing to this and you are not being forced or pressured against your better judgment.

Tr. 7.

{¶6} The trial court continued and advised Pruitt of his constitutional and

nonconstitutional rights. Tr. 10-12. Pruitt indicated to the trial court that he

understood his rights as explained by the trial court. The trial court then explained

the charges against Pruitt. Tr. 12-13. Next, the trial court explained the possible

sentences in relation to each charge and the maximum possible sentence that

Pruitt could receive. Tr. 13-15. Again, Pruitt indicated to the trial court that he

understood. Id.

{¶7} The trial court then stated:

Now for any sentence, when you get out of prison, you will have to serve a period of post-release control for a mandatory minimum of 18 months, up to a maximum of three years. Post-release control is abbreviated as PRC. PRC is a lot like parole, in case that is a word that you are familiar with, and PRC has similarities with probation as well. But what it means is that for that period of time, a year and a half, up to three years, upon your release, you would have to report to and be supervised by a parole officer. During that period of time, a parole officer would place conditions and restrictions on your conduct.

And if you were to violate those conditions, then the parole officer would have the authority to return you to prison without bringing you to court for a maximum of one half of your original sentence, depending on the number of violations you commit and what they are.

I also want you to know that if during the period of post-release control, you fail to report to a parole officer as obligated, then the prosecutor could charge you with a felony known as escape, where, if you were convicted, you would face additional prison time.

And then the last thing I want you to know about PRC is that, if the time were to come when you have finished a prison term in this case and then you’re on post-release control, and then at that point you commit a new felony, if that were to occur, then when you are sentenced for the new felony, you could get an extra prison term as punishment for violating PRC that is equal to the greater of one year or the number of years left on post-release control.

Tr. 15-17.

{¶8} Pruitt indicated to the trial court that he understood PRC, and the trial

court continued, explaining Reagan Tokes Law and its application to Pruitt’s

sentence. The trial court stated:

There is one more thing I want to tell you about the possible maximum term here.

Count one is a qualifying felony of the second degree under a law called the Reagan Tokes Law.

This law was named after a young woman who was — if I can recall correctly — murdered by somebody who just got out of prison. But that’s the background, that’s just the name of the law. The reason I want to tell you about this law is that is permits the Ohio Department of Rehabilitation and Corrections, which runs the prison, to extend whatever prison term I impose by up to 50 percent. So just let me give you an example.

Mr. Pruitt, first of all, you haven’t pleaded guilty yet. Second, assuming you do, I have no idea what your sentence is going to be. I’m not trying to preview your sentence here. I want to make sure you understand the law. So the point is, I want to give you a couple examples.

Let’s say that on the felony two, the felonious assault, I impose the minimum two years of prison on the felony itself, after the one year, remember on the spec.

If I did that, then the DRC would have the ability to extend the term I impose by up to one year, which is 50 percent of two, depending on your conduct while in prison, your rehabilitation, if any, your security classification, and other considerations.

Let me go on the higher end with a different example. Let’s say I impose the maximum of eight years, then the DRC can extend that by four because four is 50 percent of eight, and you can do the same calculation for any number between two and eight.

The point is, the DRC would be able to extend the term that I impose, not including the firearm spec, but up to that amount. Do you understand that?

Tr. 17-19.

{¶9} Pruitt indicated that he understood how the Reagan Tokes Law would

apply to his sentence. Next the trial court stated: “By the way, this law — the

possibility of extending your prison term — does not apply to the felony three.”

Tr. 19. B. Sentence Hearing

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2025 Ohio 1557, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-pruitt-ohioctapp-2025.