State v. Shockey

2025 Ohio 328
CourtOhio Court of Appeals
DecidedFebruary 3, 2025
Docket9-23-22
StatusPublished
Cited by1 cases

This text of 2025 Ohio 328 (State v. Shockey) 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. Shockey, 2025 Ohio 328 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Shockey, 2025-Ohio-328.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT MARION COUNTY

STATE OF OHIO, CASE NO. 9-23-22 PLAINTIFF-APPELLEE,

v.

DOUGLAS SHOCKEY, OPINION

DEFENDANT-APPELLANT.

Appeal from Marion County Common Pleas Court General Division Trial Court No. 21CR0241

Judgment Affirmed

Date of Decision: February 3, 2025

APPEARANCES:

April F. Campbell for Appellant

David Stamolis for Appellee Case No. 9-23-22

WALDICK, P.J.

{¶1} This case is before this court on remand from the Supreme Court of

Ohio. State v. Shockey, 2024-Ohio-5176. Based on the Supreme Court of Ohio’s

instructions, we will reevaluate Shockey’s first assignment of error related to

facially deficient verdict forms under the plain error standard as articulated in State

v. Mays, 2024-Ohio-4616. For the reasons that follow, we now affirm the judgment

of the trial court in its entirety.1

Background

{¶2} This case was originally before this court on appeal from the March 13,

2023 judgment entry of the Marion County Common Pleas Court convicting

defendant-appellant, Douglas Shockey (“Shockey”), of two counts of Assault

against a Peace Officer and one count of Obstructing Official Business. In

Shockey’s direct appeal to this court, he argued, inter alia, that the verdict forms

were deficient because the forms did not contain the aggravating elements or the

degrees of the offenses. Shockey argued that pursuant to R.C. 2945.75(A)(2) and

the Supreme Court of Ohio’s case law interpreting the statute such as State v.

1 Shockey asserted six assignments of error in his direct appeal. We overruled all assignments of error except for the first assignment of error related to verdict forms. The Supreme Court of Ohio did not alter our opinion with regard to the other assignments of error, therefore the original opinion remains controlling on those issues.

-2- Case No. 9-23-22

Pelfrey, 2007-Ohio-256, his convictions had to be reduced to the lowest forms of

the offenses.

{¶3} We analyzed Shockey’s arguments and noted that the Supreme Court

of Ohio’s jurisprudence had presented “seemingly conflicting legal authority on

verdict forms,” particularly as to how the plain error doctrine should be applied, if

at all, given that R.C. 2945.75(A)(2) mandates that “A guilty verdict shall state

either the degree of the offense of which the offender is found guilty, or that such

additional element or elements are present. Otherwise, a guilty verdict constitutes a

finding of guilty of the least degree of the offense charged.” Ultimately we followed

what was, at the time, the Supreme Court of Ohio’s most recent pronouncement on

the topic of verdict forms, State v. McDonald, 2013-Ohio-5042, wherein the Court

indicated that review of issues related to verdict forms were confined to the verdict

form itself. Thus we held that we could not look to the evidence to overcome any

deficiencies in the verdict forms.

{¶4} Based on McDonald, we determined Shockey’s verdict forms were

insufficient to convict him of the elevated offense of Assault against a Peace Officer

because the additional elements that enhanced the crimes of Assault (that the victims

were peace officers) were not present in the verdict form and the degrees of the

offenses were not stated. Similarly, we held that the verdict form was insufficient to

convict Shockey of the elevated offense of Obstructing Official Business because

the additional element (that the violation created a risk of physical harm to any

-3- Case No. 9-23-22

person) was not present in the verdict form and the degree of the offense was not

stated. State v. Shockey, 2024-Ohio-296, ¶ 42 (3d Dist).

{¶5} In State v. Mays, 2024-Ohio-4616, the Supreme Court of Ohio clarified

that plain error review should apply in this situation, permitting us to look beyond

the four corners of the verdict form. The Court held that the defendant had the

burden to object to a deficient verdict form, and if the defendant did not, we apply

a plain error analysis rather than the statutory remedy. Shockey was summarily

reversed for us to apply Mays. State v. Shockey, 2024-Ohio-5176. We will now

address Shockey’s first assignment of error related to his verdict forms, applying

the Supreme Court of Ohio’s holding in Mays.

First Assignment of Error

Shockey's convictions and sentences should be reversed because the verdict forms do not comply with R.C. 2945.75: There was no special finding or degree of offense listed in the verdict forms to convict Shockey and sentence him, on anything more than three misdemeanors.

{¶6} In his first assignment of error, Shockey argues that all three of his

verdict forms did not contain the degrees of the offenses or the additional enhancing

elements of the offenses pursuant to R.C. 2945.75(A)(2), thus he argues that he

could only be convicted of the lowest forms of the offenses pursuant to State v.

Pelfrey, 2007-Ohio-256.

-4- Case No. 9-23-22

{¶7} In Shockey’s original appeal, we found that his verdict forms were

deficient, and we do so again here in the same analysis:

A plain reading of the verdict forms establishes that Counts 2 and 3 related to Assault do not mention the aggravating element that the victim was a peace officer in the performance of his official duties. The verdict forms also do not cite the statutory subsection related to that enhancing element, or cite the degree of the offense.

Similarly, Count 3 related to Obstructing Official Business does not state the aggravating element of creating a risk of physical harm to any person. In addition, the verdict form did not cite the degree of the offense.

State v. Shockey, 2024-Ohio-296, ¶ 38-39 (3d Dist.).

{¶8} In the prior appeal, we applied the Supreme Court of Ohio’s holding in

State v. McDonald, 2013-Ohio-5042, and determined that we could only look at the

four corners of the verdict form to determine whether there was error under R.C.

2945.75(A)(2). Thus we found that there was error, that the error was reversible,

and that the convictions had to be reduced to the lowest forms of the offenses.

However, in reaching our holding, we noted that:

we are not unsympathetic to the State’s argument that if we applied [a plain error analysis] and looked outside of the jury verdict form, plain error would not be apparent here given that the jury verdict forms referenced the indictment and given that the evidence was undisputed that the victims were police officers acting in their official capacity.

Shockey at ¶ 41.

-5- Case No. 9-23-22

{¶9} Now, the Supreme Court of Ohio has clearly stated that plain error

review should apply in this instance. “Under plain-error review, three elements must

be met in order to find reversible error. There must first be a deviation from a legal

rule, that deviation must be an obvious defect in trial proceedings, and the deviation

must have affected substantial rights.” Mays at ¶ 27.

{¶10} Here, there was a deviation from a legal rule when the verdict forms

did not comply with R.C. 2945.75(A)(2). However, Shockey did not object to the

error, and we do not find that the errors related to the verdict forms affected

Shockey’s substantial rights.

{¶11} The evidence was clear that Shockey “kicked officers [acting in their

official capacity] multiple times and he kicked one officer after he said he would no

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