State v. Sawyer

Ohio Court of Appeals·Decided April 17, 2026·No. 2025-CA-37·Published

Opinion

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

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

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

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. Coffman, 2021-Ohio-1601, ¶ 27 (2d Dist.). Consequently, a guilty plea waives all appealable errors, except to the extent that the errors precluded the defendant from knowingly, intelligently, and voluntarily entering his or her guilty plea. Coffman at ¶ 27; State v. Rogan, 2025-Ohio-2468, ¶ 11 (2d Dist.). Sawyer does not claim that his guilty plea was not knowing, intelligent, and voluntary. Consequently, he waived his right to challenge the trial court’s ruling on his motion to suppress when he entered his guilty plea.

{¶ 13} Sawyer’s second assignment of error is overruled.

III. Amenability Determination

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