State v. Sawyer

CourtOhio Court of Appeals
DecidedApril 17, 2026
Docket2025-CA-37
StatusPublished

This text of State v. Sawyer (State v. Sawyer) 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. Sawyer, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Sawyer, 2026-Ohio-1398.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT GREENE COUNTY

STATE OF OHIO : : C.A. No. 2025-CA-37 Appellee : : Trial Court Case No. 2024 CR 0423 v. : : (Criminal Appeal from Common Pleas WILLIAM J. SAWYER : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on April 17, 2026, the judgment of the

trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

CHRISTOPHER B. EPLEY, JUDGE

HUFFMAN, J., and HANSEMAN, J., concur. OPINION GREENE C.A. No. 2025-CA-37

KRISTIN L. ARNOLD, Attorney for Appellant MEGAN A. HAMMOND, Attorney for Appellee

EPLEY, J.

{¶ 1} After being bound over from juvenile court, William J. Sawyer pleaded guilty in

the Greene County Court of Common Pleas, General Division, to two counts of rape, three

counts of pandering sexually-oriented material involving a minor, and two counts of illegal

use of a minor in nudity-oriented material or performance. The trial court imposed the agreed

sentence of four to six years in prison and designated him a Tier III sex offender.

{¶ 2} Sawyer appeals from his convictions, claiming that the juvenile division erred in

transferring jurisdiction to the general division for prosecution as an adult and that the trial

court erred in denying his motion to suppress. For the following reasons, the trial court’s

judgment is affirmed.

I. Facts and Procedural History

{¶ 3} According to Detective Christoper Sticka’s testimony at the motion to suppress

hearing, the investigation into Sawyer began after the Greene County Sheriff’s Office

received a referral from the Internet Crimes Against Children (“ICAC”) task force. ICAC

provided an IP address that had been used to upload three photos and one video showing

a prepubescent child in a state of nudity and involved in a sexual act.

{¶ 4} The sheriff’s office quickly suspected Sawyer, then 17 years old, of uploading

the unlawful material. Detectives determined that the IP address was associated with

Sawyer’s residence, and they obtained a search warrant for the home. When detectives

2 went to the house on February 23, 2024, Sawyer’s parents identified a cell phone number

that had been included in the ICAC report as belonging to Sawyer.

{¶ 5} Sawyer’s father agreed to allow Sticka to speak with his son, and he

accompanied the detective to Sawyer’s high school to get Sawyer out of school. After Sticka

introduced himself to Sawyer, Sawyer agreed to go with deputies to the sheriff's office to

speak with Sticka. Upon arrival, Sawyer was placed in an interview room. Sawyer’s father

also went to the sheriff’s office, and after agreeing to allow Sticka to speak with Sawyer

privately, he waited in the lobby.

{¶ 6} Before questioning Sawyer, Detective Sticka informed Sawyer of his Miranda

rights using a juvenile pre-interview form. Sawyer orally indicated that he understood his

rights, placed a checkmark after each right, and signed the form. He did not state that he

wanted a lawyer. Detective Sticka proceeded to interview Sawyer, during which Sawyer

admitted to uploading the obscene material and committing sexual assaults over several

years against a relative, who was then 12 years old. Sawyer was arrested following the

interview and taken to the Greene County Juvenile Detention Center.

{¶ 7} Two days later, Sawyer was charged by complaint in juvenile court with two

counts of rape, both felonies of the first degree if committed by an adult. On March 4, 2024,

the State filed a motion for the juvenile court to relinquish jurisdiction, to transfer jurisdiction

to the general division for prosecution as an adult, and to schedule a preliminary hearing.

Following a hearing on April 4, 2024, the juvenile court found that there was sufficient

evidence to support the finding of probable cause to believe that Sawyer had committed two

counts of rape. The court ordered an investigation, including a psychological evaluation, and

scheduled an amenability hearing. At defense counsel’s request, a second evaluation was

conducted. The court held the amenability hearing on June 28, 2024. On July 8, 2024, after

3 considering the evidence and weighing the statutory factors, the juvenile court granted the

State’s motion to relinquish jurisdiction and transferred the action to the general division for

the prosecution of Sawyer as an adult.

{¶ 8} Later that month, Sawyer was indicted on two counts of rape, three counts of

pandering sexually-oriented material involving a minor, and two counts of illegal use of a

minor in nudity-oriented material or performance. He moved to suppress (1) evidence seized

from his residence on February 23, 2024 pursuant to a search warrant, (2) evidence seized

on February 23, 2024 from his Discord account, (3) statements he made as a result of his

arrest and interrogation, and (4) evidence seized from his phone on or about March 4, 2024.

Because the trial judge had signed the residential search warrant, the matter was transferred

to another judge to resolve the suppression issue only. After a hearing, the motion to

suppress was denied in its entirety.

{¶ 9} Sawyer’s jury trial was scheduled for May 5, 2025. On that date, however, he

entered a guilty plea to the offenses charged in the indictment. In exchange for the plea, the

State agreed to a mandatory prison term of four to six years. Sawyer acknowledged that he

would be required to register for life as a Tier III sex offender. The trial court accepted

Sawyer’s plea and sentenced him as agreed by the parties.

{¶ 10} Sawyer appeals from his convictions, raising two assignments of error. We

address them in reverse order

II. Motion to Suppress

{¶ 11} In his second assignment of error, Sawyer challenges the trial court’s denial of

his motion to suppress on two grounds. First, he claims that the statements he made during

his interrogation on February 23, 2024, were involuntary and obtained in violation of his

Miranda rights. Second, he asserts that the evidence obtained from his residence and

4 Discord account should have been suppressed, because the search warrants authorizing

the searches were not supported by probable cause and the warrants failed to establish a

connection between the searches and the alleged criminal conduct. The State responds that

by pleading guilty, Sawyer waived any challenge to the suppression ruling. We agree with

the State.

{¶ 12} “The plea of guilty is a complete admission of the defendant’s guilt.”

Crim.R. 11(B)(1). “When a criminal defendant has solemnly admitted in open court that he

is in fact guilty of the offense with which he is charged, he may not thereafter raise

independent claims relating to the deprivation of constitutional rights that occurred prior to

the entry of the guilty plea.” State v. Spates, 64 Ohio St.3d 269, 272 (1992); State v.

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Bluebook (online)
State v. Sawyer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sawyer-ohioctapp-2026.