State v. Sweet

2026 Ohio 1082
CourtOhio Court of Appeals
DecidedMarch 27, 2026
DocketL-25-00111
StatusPublished

This text of 2026 Ohio 1082 (State v. Sweet) 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. Sweet, 2026 Ohio 1082 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Sweet, 2026-Ohio-1082.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio Court of Appeals No. {48}L-25-00111

Appellee Trial Court No. CR020250379

v.

Jason M. Sweet DECISION AND JUDGMENT

Appellant Decided: March 27, 2026

*****

Julia R. Bates, Lucas County Prosecuting Attorney, and, Brenda J. Majdalani, Assistant Prosecuting Attorney, for appellee.

Michael H. Stahl, for appellant.

SULEK, J.

{¶ 1} Appellant, Jason M. Sweet, appeals the May 2, 2025 judgment of the Lucas

County Court of Common Pleas, convicting him of numerous child-pornography offenses

and imposing an aggregate prison term of a minimum of 48 years and a maximum of 52

years. For the following reasons, Sweet’s appeal is affirmed. I. Background

{¶ 2} Jason Sweet entered a plea of guilty to four counts of pandering obscenity

involving a minor or impaired person, violations of R.C 2907.321(A)(1) and (C), second-

degree felonies (Counts 1 through 4); five counts of pandering sexually-oriented matter

involving a minor or impaired person, violations of R.C. 2907.322(A)(1) and (C),

second-degree felonies (Count 5 through 9); and four counts of illegal use of a minor or

impaired person in nudity-oriented material or performance, violations of R.C.

2907.323(A)(1) and (B), second-degree felonies (Counts 10 through 13). The trial court

accepted Sweet’s plea, made a finding of guilty, referred the matter for a presentence

investigation report, and continued the matter for sentencing.

{¶ 3} The trial court ordered Sweet to serve a minimum prison term of eight years

and a maximum prison term of 12 years as to each Count. It ordered that the terms

imposed for Counts 1 through 4 and Counts 5 through 9 be served concurrently to each

other. It ordered that the terms imposed for Counts 1 through 4, Counts 5 through 9,

Count 10, Count 11, Count 12, and Count 13 be served consecutively to each other. The

aggregate prison term imposed was a minimum of 48 years and a maximum of 52 years.

{¶ 4} Sweet appealed. He assigns the following errors for review:

I. The trial court erred in imposing consecutive sentences[.]

II. Mr. Sweet received ineffective assistance of counsel concerning pleading to the indictment, failing to mitigate, and failing to correctly argue proportionality at sentencing under the United States Constitution and sections 10 & 16, Art. I of the Ohio Constitution, which resulted in a plea that was not knowing, intelligent, or voluntary[.]

2. II. Law and Analysis

{¶ 5} Sweet claims error in the trial court’s imposition of consecutive sentences

and argues that the ineffective assistance of counsel led him to enter a plea that was not

knowing, intelligent, or voluntary.

A. Consecutive Sentences

{¶ 6} In his first assignment of error, Sweet argues that the trial court erred in

imposing consecutive sentences. Appellate courts review a challenge to a felony

sentence under R.C. 2953.08(G)(2). R.C. 2953.08(G)(2) provides that the court may

increase, reduce, or otherwise modify a sentence or may vacate the sentence and remand

the matter to the sentencing court for resentencing if it clearly and convincingly finds

either of the following:

(a) That the record does not support the sentencing court’s findings under division (B) or (D) of section 2929.13, division (B)(2)(e) or (C)(4) of section 2929.14, or division (I) of section 2929.20 of the Revised Code, whichever, if any, is relevant;

(b) That the sentence is otherwise contrary to law.

{¶ 7} Sweet’s challenge is to the imposition of consecutive sentences under R.C.

2929.14(C)(4). Under that section, where a trial court imposes multiple prison terms for

convictions of multiple offenses, it may require the offender to serve the prison terms

consecutively if it finds that “consecutive service is necessary to protect the public from

future crime or to punish the offender and that consecutive sentences are not

disproportionate to the seriousness of the offender’s conduct and to the danger the

offender poses to the public, . . .” and if it also finds any of the following:

3. (a) The offender committed one or more of the multiple offenses while the offender was awaiting trial or sentencing, was under a sanction imposed pursuant to section 2929.16, 2929.17, or 2929.18 of the Revised Code, or was under post-release control for a prior offense.

(b) At least two of the multiple offenses were committed as part of one or more courses of conduct, and the harm caused by two or more of the multiple offenses so committed was so great or unusual that no single prison term for any of the offenses committed as part of any of the courses of conduct adequately reflects the seriousness of the offender’s conduct.

(c) The offender’s history of criminal conduct demonstrates that consecutive sentences are necessary to protect the public from future crime by the offender.

{¶ 8} In other words, this statute requires the trial court to make three statutory

findings before imposing consecutive sentences. State v. Beasley, 2018-Ohio-493, ¶ 252;

State v. Bonnell, 2014-Ohio-3177, ¶ 26. It must find that (1) consecutive sentences are

necessary to protect the public or to punish the offender; (2) consecutive sentences are

not disproportionate to the seriousness of the offender’s conduct and to the danger that

the offender poses to the public; and (3) R.C. 2929.14(C)(4)(a), (b), or (c) applies.

Beasley at ¶ 252. “[T]he trial court must make the requisite findings both at the

sentencing hearing and in the sentencing entry.” (Emphasis in original.) Id. at ¶ 253,

citing Bonnell at ¶ 37. While “a word-for-word recitation of the language of the statute is

not required . . .,” a reviewing court must be able to discern that the trial court engaged in

the correct analysis. Bonnell at ¶ 29.

{¶ 9} Here, the trial court made the required findings both at the sentencing

hearing and in its judgment. It found (1) “[c]onsecutive sentences are necessary to

protect the public from future crime or to punish the offender,” (2) consecutive sentences

4. are “not disproportionate to the seriousness of the offender’s conduct and the danger the

offender poses,” and (3) “defendant was on bond awaiting trial when these events

occurred” and “at least two of the multiple offenses were committed as part of one or

more courses of conduct and the harm caused by two or more of the multiple offenses so

committed was so great or unusual that no single prison term for any of the offenses

committed as part of any of the courses of conduct adequately reflects the seriousness of

the offender’s conduct”—i.e., both R.C. 2929.14(C)(4)(a) and (b) apply.

{¶ 10} An appellate court may modify or vacate the imposition of consecutive

sentences, but only when it concludes that the record clearly and convincingly does not

support the trial court’s findings. State v. Glover, 2024-Ohio-5195, ¶ 2, 43, citing R.C.

2953.08(G)(2). It may not consider the defendant’s aggregate sentence, nor may it

“simply substitute its view of an appropriate sentence for that of the trial court.” Id. at ¶

43-44. “Rather, the appellate court must limit its review to the trial court’s R.C.

2929.14(C)(4) consecutive-sentencing findings.” Id. at ¶ 43. In doing so, “[i]t must

examine the evidence in the record that supports the trial court’s findings.” Id. at ¶ 45.

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Bluebook (online)
2026 Ohio 1082, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sweet-ohioctapp-2026.