State v. Slepsky

2026 Ohio 709
CourtOhio Court of Appeals
DecidedMarch 2, 2026
Docket2025-G-0014
StatusPublished

This text of 2026 Ohio 709 (State v. Slepsky) 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. Slepsky, 2026 Ohio 709 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Slepsky, 2026-Ohio-709.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT GEAUGA COUNTY

STATE OF OHIO, CASE NO. 2025-G-0014

Plaintiff-Appellee, Criminal Appeal from the - vs - Court of Common Pleas

JASON A. SLEPSKY, Trial Court No. 2023 C 000156 Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: March 2, 2026 Judgment: Affirmed

James R. Flaiz, Geauga County Prosecutor, and Nicholas A. Burling, Assistant Prosecutor, Courthouse Annex, 231 Main Street, Suite 3A, Chardon, OH 44024 (For Plaintiff-Appellee).

Catherine R. Meehan, Patituce & Associates, L.L.C., 16855 Foltz Industrial Parkway, Suite 1, Strongsville, OH 44149 (For Defendant-Appellant).

ROBERT J. PATTON, J.

{¶1} Defendant-appellant, Jason A. Slepsky (“Slepsky”), appeals from the

judgment of the Geauga County Court of Common Pleas sentencing him to an aggregate

mandatory prison term of 48 months as a result of his convictions of aggravated vehicular

homicide, a felony of the third degree, and two counts of aggravated vehicular assault,

third-degree felonies. Slepsky also appeals the trial court’s ruling granting appellee, the

State of Ohio’s (“State”), motion in limine. For the following reasons, we affirm.

{¶2} Slepsky presents three assignments of error for review. In his first

assignment of error, Slepsky asserts that the trial court erred when it granted the State’s motion in limine. Generally, a no contest plea waives appellate review of a ruling on a

motion in limine. State v. Engle, 1996-Ohio-179, ¶ 16 (Resnick, J., concurring). However,

it is apparent from the record that the State and Slepsky intended to preserve this issue

on appeal. Moreover, the trial court’s decision precluding defense counsel from calling an

expert to testify about the absence of marijuana metabolite in Slepsky’s blood and any

lack of impairment was more akin to a decision on a motion to suppress, insofar as

the evidence and testimony would not have become relevant and admissible at trial under

the circumstances. Thus, the trial court’s decision was final and the issue was preserved

for appeal. Upon review of the limited record, this court concludes that the trial court did

not err, or otherwise abuse its discretion, when it granted the State’s motion in limine.

{¶3} Next, Slepsky contends that the trial court erred when it accepted his no

contest plea where the State’s explanation of circumstances was insufficient to support

the convictions. We conclude that the indictment, bill of particulars, and the State’s

recitation of the facts were sufficient to support Slepsky’s convictions in this case.

Additionally, the State’s explanation of circumstances did not negate any element of the

offenses.

{¶4} In his final assignment of error, Slepsky contends that the trial court failed

to comply with Crim.R. 11 by failing to advise him of the effect of his no contest plea. The

record indicates otherwise. Specifically, the transcript of the hearing in conjunction with

the signed, written plea agreement, illustrate that Slepsky was advised of and understood

the effect of his plea.

{¶5} As none of Slepsky’s assignments of error are meritorious, the judgment of

the Geauga County Court of Common Pleas is affirmed.

PAGE 2 OF 23

Case No. 2025-G-0014 Substantive and Procedural Facts

{¶6} On December 18, 2023, the Geauga County Grand Jury, in a six-count

indictment, charged Slepsky with: aggravated vehicular homicide, a second-degree

felony, in violation of R.C. 2903.06(A)(1)(a) (“Count 1”); aggravated vehicular assault, a

third-degree felony, in violation of R.C. 2903.08(A)(1)(a) (“Count 2”); aggravated vehicular

assault, a third-degree felony, in violation of R.C, 2903.08(A)(1)(a) (“Count 3”); operating

a vehicle under the influence of alcohol, a drug of abuse, or a combination of them, a first-

degree misdemeanor, in violation of R.C. 4511.19(A)(1)(a) (“Count 4”); operating a

vehicle under the influence of alcohol, a drug of abuse, or a combination of them, a first-

degree misdemeanor, in violation of R.C. 4511.19(A)(1)(j)(viii) (“Count 5”); and failure to

stop at a stop sign, a minor misdemeanor, in violation of R.C. 4511.43(A) (“Count 6”).1

{¶7} On January 18, 2024, Slepsky pleaded not guilty at arraignment. On April

11, 2024, at Slepsky’s request, the trial court modified his bond conditions and removed

the requirement that Slepsky wear a Secure Continuous Remote Alcohol Monitor

(“SCRAM”) ankle bracelet. As a condition of his bond, the trial court ordered Slepsky to

submit to random drug screening.

{¶8} On October 23, 2024, the State filed a bill of particulars and filed a motion

to amend the indictment. The motion to amend the indictment sought to dismiss Count 4.

The trial court granted the State’s motion to amend the indictment on October 25, 2024.

{¶9} On October 28, 2024, the State filed a motion in limine seeking to exclude

testimony or other evidence regarding: 1) the testing of Slepsky’s blood; 2) the effect

marijuana metabolite may or may not have on the impairment of an individual; 3) how

1. The charges were originally filed in the Chardon Municipal Court on September 26, 2023 and were bound over to the Geauga County Court of Common Pleas on October 11, 2023. PAGE 3 OF 23

Case No. 2025-G-0014 long a metabolite remains in a person's urine after use; and 4) when Slepsky last used

marijuana prior to the incident. Slepsky opposed the motion. On January 21, 2025, the

trial court granted the State’s motion in limine. Specifically, the trial court stated, “[g]iven

the wording of [R.C. 4511.19(A)(1)], taken in conjunction with [this court]’s holding in State

v. Naylor, 2024-Ohio-1648” the evidence would be excluded. The court below also

indicated that the order did not “interfere with Defense counsel’s ability to argue against

the results of the urine analysis” regarding whether the marijuana metabolite in Slepsky’s

urine exceeded the statutory limit.

{¶10} On February 2, 2025, Slepsky pleaded no contest to aggravated vehicular

homicide, a violation of R.C. 2903.06(A)(2), which the parties described as a lesser

included offense to the offense originally charged in the indictment (“Amended Count 1”),

a felony of the third degree; aggravated vehicular assault, a third-degree felony (“Count

2”), and aggravated vehicular assault, a third-degree felony (“Count 3”). The State agreed

to dismiss Counts 5 and 6 of the indictment.

{¶11} The State offered the following factual basis at the plea hearing:

We would have shown that on September 26th of 2023, Mr. Slepsky was operating a vehicle. During the operation of that vehicle, he struck the side of an ambulance, flipping it over that caused the death of the patient who was in the back of the ambulance, and also caused serious physical harm to the driver and the EMT who was in the back with the patient. An accident reconstruction determined that he was traveling at a speed that would have been consistent with going through the stop sign instead of stopping at it.

And then the Troopers obtained a urine sample from him, sent it out for testing, and it came back with the presence of approximately 52 nanograms per millimeter of marijuana metabolite in his urine at the time of the crash.

PAGE 4 OF 23

Case No. 2025-G-0014 Dkt. 195, T.p. Plea Hearing Transcript, p. 16. There was no objection to the factual basis.

The trial court ordered a presentence investigation (“PSI”).

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Bluebook (online)
2026 Ohio 709, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-slepsky-ohioctapp-2026.