State v. Sampson

Ohio Court of Appeals·Decided August 14, 2026·No. 115478·Published

Opinion

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, :

No. 115478

v. :

LORINZO SAMPSON, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: APPLICATION DENIED RELEASED AND JOURNALIZED: August 14, 2026

Cuyahoga County Court of Common Pleas Case Nos. CR-24-694656-A and CR-25-698527-A Application for Reopening Motion No. 596575

Appearances:

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

Lorinzo Sampson, pro se.

MARY J. BOYLE, J.:

Lorinzo Sampson (“Sampson”), pro se, has filed an application for reopening pursuant to App.R. 26(B) and State v. Murnahan, 63 Ohio St.3d 60

(1991), based on claims of ineffective assistance of appellate counsel. Sampson is attempting to reopen this court’s judgment in State v. Sampson, 2026-Ohio-1381 (8th Dist.), in which this court affirmed the trial court’s imposition of consecutive sentences. For the reasons that follow, we deny Sampson’s application to reopen the appeal.

I. Procedural and Factual History In August 2024, Sampson was named in a two-count indictment in Cuyahoga C.P. No. CR-24-694656-A, charging him with having weapons while under disability and tampering with evidence. At the time of the indictment, Sampson was serving a term of community-control sanctions following his convictions in two prior cases.

In January 2025, Sampson was named in a four-count indictment in Cuyahoga C.P. No. CR-25-698527-A, charging him with felonious assault, domestic violence, and two counts of having weapons while under disability.

In February 2025, Sampson accepted the terms of a negotiated plea agreement in Case No. CR-24-694656-A and pleaded guilty to a single count of attempted having weapons while under disability, with a forfeiture specification, as amended in Count 1 of the indictment. The remaining count was nolled.

In July 2025, Sampson accepted the terms of a negotiated plea agreement in Case No. CR-25-698527-A and pleaded guilty to a single count of attempted having weapons while under disability as amended in Count 2 of the indictment. The remaining counts were nolled.

At the conclusion of a joint sentencing hearing, Sampson was sentenced to an 18-month term of imprisonment in Case No. CR-24-694656-A and an 18- month term of imprisonment in Case No. CR-25-698527-A. The sentences were ordered to be served consecutively for an aggregate prison term of 36 months. At the conclusion of the sentencing hearing, the trial court expressed that it would modify the individual prison terms imposed in each case to a period of 16 months if it could confirm that Sampson successfully completed rehabilitative programming during his time in county jail.

In August 2025, Sampson filed a direct appeal from his convictions and sentence in Case Nos. CR-24-694656-A and CR-25-698527-A. Therein, Sampson raised three assignments of error, arguing (1) the trial court was neither neutral nor impartial, (2) the trial court’s sentence was contrary to law, and (3) the trial court violated his Sixth Amendment rights to effective assistance of counsel when it failed to permit him to hire counsel of his choosing. Upon review, this court found no merit to Sampson’s claims and affirmed the trial court’s judgment. State v. Sampson, 2026-Ohio-1381 (8th Dist.).

On June 23, 2026, Sampson filed a timely application to reopen his appeal, asserting that “appellate counsel’s inadequate performance compromised [his] right to a direct appeal.” Specifically, Sampson argues that appellate counsel rendered ineffective assistance of counsel by failing to raise the following proposed assignments of error:

1. Trial court committed reversible error when it asserted it would inquire into whether appellant successfully fulfilled program obligations in order to consider modifying appellant’s sentence.

However, the trial court made no inquiry, and lied to defendant about its authority to make a modification to his sentence.

2. Trial court abused its discretion when it failed to assign appellant’s case to the mental health and developmental disabilities docket in violation of his due process rights of the 14th Amendment of the U.S.

Const.

On July 17, 2026, the State filed a brief in opposition to the application for reopening, arguing that Sampson “has shown no genuine issue of appellate counsel being ineffective.”

II. Law and Analysis

A. Standard of Review

Under App.R. 26(B), a defendant in a criminal case may apply to reopen his or her direct appeal of the judgment of conviction and sentence based on a claim of ineffective assistance of appellate counsel. The application must be filed within 90 days from journalization of the appellate judgment unless the applicant shows good cause for filing at a later time. App.R. 26(B)(1).

App.R. 26(B) establishes a two-stage procedure for adjudicating claims of ineffective assistance of appellate counsel. State v. Leyh, 2022-Ohio-292, ¶ 19. An applicant must first make a threshold showing that appellate counsel was ineffective. Id. at ¶ 19, 35. At this stage, an applicant is “not required to conclusively establish ineffective assistance of appellate counsel[.]” Id. at ¶ 35. Rather, “[t]he burden is on the applicant to demonstrate a ‘genuine issue’ as to whether there is a ‘colorable claim’ of ineffective assistance of appellate counsel.” Id. at ¶ 21, quoting State v. Spivey, 84 Ohio St.3d 24, 25 (1998).

If the applicant makes the required threshold showing, demonstrating that “there is at least a genuine issue — that is, legitimate grounds —to support the claim that the applicant was deprived of the effective assistance of counsel on appeal,” then the application shall be granted and the appeal reopened. Id. at ¶ 25, citing App.R. 26(B)(5). The matter then

“proceeds to the second stage of the procedure, which ‘involves filing appellate briefs and supporting materials with the assistance of new counsel, in order to establish that prejudicial errors were made in the trial court and that ineffective assistance of appellate counsel in the prior appellate proceedings prevented these errors from being presented effectively to the court of appeals.’”

Id. at ¶ 22, quoting 1993 Staff Notes to App.R. 26(B).

Claims of ineffective assistance of appellate counsel under App.R. 26(B) are subject to the two-pronged analysis enunciated in Strickland v. Washington, 466 U.S. 668 (1984). See State v. Simpson, 2020-Ohio-6719, ¶ 14; Leyh at ¶ 23 (O’Connor, C.J., concurring). In accordance with the Strickland analysis, an applicant must show that (1) appellate counsel’s performance was objectively unreasonable, and (2) there is “a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Smith v. Robbins, 528 U.S. 259, 285-286 (2000). “A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Strickland at 694.

In considering Sampson’s application, we are mindful that appellate counsel is afforded deference in determining which issues to argue on appeal. State v. Burke, 2002-Ohio-5310, ¶ 7. As this court has previously explained:

With respect to claims of ineffective assistance of appellate counsel, the United States Supreme Court has upheld the appellate advocate’s prerogative to decide strategy and tactics by selecting the most promising arguments and focusing on one central issue or, at most, a few key issues. State v. Barrow, 2015-Ohio-4579, ¶ 7 (8th Dist.), citing Jones v. Barnes, 463 U.S. 745, 751-52 (1983). See also State v. Ware, 2014-Ohio-815, ¶ 5 (8th Dist.) (“Appellate counsel cannot be considered ineffective for failing to raise every conceivable assignment of error on appeal.”).

State v. Doumbas, 2016-Ohio-956, ¶ 6 (8th Dist.).

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Related

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State v. Carlisle
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State v. Jones
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State v. Lee
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State v. Ellis
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State v. Simpson (Slip Opinion)
2020 Ohio 6719 (Ohio Supreme Court, 2020)
State v. Leyh (Slip Opinion)
2022 Ohio 292 (Ohio Supreme Court, 2022)
State v. Murnahan
584 N.E.2d 1204 (Ohio Supreme Court, 1992)
State v. Spivey
701 N.E.2d 696 (Ohio Supreme Court, 1998)
State v. Burke
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State v. Sampson
2026 Ohio 1381 (Ohio Court of Appeals, 2026)