State v. Tate

Procedural entryThis page is a short order in State v. Tate. Read the opinion of the Court — 2024 Ohio 5319
Ohio Court of Appeals·Decided June 3, 2026·No. C-250351·Published

Opinion

[Cite as State v. Tate, 2026-Ohio-2067.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250351 TRIAL NO. B-2001014 Plaintiff-Appellee, :

vs. :

TONY TATE, : JUDGMENT ENTRY

Defendant-Appellant. :

This cause was heard upon the appeal, the record, and the briefs. For the reasons set forth in the Opinion filed this date, the judgment of the trial court is affirmed. Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed under App.R. 24. The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk: Enter upon the journal of the court on 6/3/2026 per order of the court.

By:_______________________ Administrative Judge [Cite as State v. Tate, 2026-Ohio-2067.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250351 TRIAL NO. B-2001014 Plaintiff-Appellee, :

vs. : OPINION TONY TATE, :

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: June 3, 2026

Connie Pillich, Hamilton County Prosecuting Attorney, and John D. Hill, Jr., Assistant Prosecuting Attorney, for Plaintiff-Appellee,

Arenstein & Gallager and William Gallager, for Defendant-Appellant. OHIO FIRST DISTRICT COURT OF APPEALS

CROUSE, Presiding Judge.

{¶1} Following guilty pleas and the trial court’s imposition of an agreed

aggregate sentence, defendant-appellant Tony Tate appeals his convictions for three

counts of aggravated assault, accompanying firearm specifications, and carrying a

concealed weapon. Tate raises two assignments of error for our review, arguing that

the trial court erred in imposing consecutive sentences on two firearm specifications

and that his trial counsel was ineffective for failing to file a motion to dismiss on

speedy-trial grounds.

{¶2} We hold that the doctrine of invited error does not bar Tate from

challenging an agreed sentence on appeal where that sentence was not authorized by

law. We further hold that the trial court erred in imposing consecutive sentences on

the two firearm specifications where the underlying felonies that the specifications

accompanied arose out of the same act or transaction. But because Tate failed to object

to this error below, and because he has not established that plain error resulted or that

we must correct the error to prevent a manifest miscarriage of justice, we ultimately

overrule the assignment of error challenging the sentences imposed on the firearm

specifications. Because we also hold that Tate’s trial counsel was not ineffective for

failing to file a motion to dismiss, we overrule Tate’s second assignment of error and

affirm the trial court’s judgment.

I. Factual and Procedural History

{¶3} On February 27, 2020, an indictment was issued against Tate charging

him with three second-degree-felony counts of felonious assault in violation of R.C.

2903.11(A)(2), each with an accompanying firearm specification; three second-

degree-felony counts of felonious assault in violation of R.C. 2903.11(A)(1), each with

an accompanying firearm specification; carrying a concealed weapon, a fourth-degree

3 OHIO FIRST DISTRICT COURT OF APPEALS

felony in violation of R.C. 2923.12(A)(2); having a weapon under disability, a third-

degree felony in violation of R.C. 2923.13(A)(2); and tampering with evidence, a third-

degree felony in violation of R.C. 2921.12(A)(1).

{¶4} The bill of particulars alleged that Tate, armed with a concealed

handgun that he was legally precluded from possessing, shot and seriously injured

A.J., V.R., and J.T. It further alleged that J.T. was an innocent bystander that was

struck when Tate missed his intended targets, A.J. and V.R.

{¶5} Shortly after the indictment was issued, several continuances were

entered on the court’s order due to the coronavirus shutdown. In August 2020,

retained counsel entered a notice of appearance for Tate. Despite being represented,

Tate filed three pro se motions in December 2020: a motion to suppress, a motion to

request camera footage, and a motion to request more evidence.

{¶6} Between January 2021 and August 2022, 13 continuances were

obtained upon Tate’s request. At a hearing on August 31, 2022, retained counsel told

the trial court that Tate wished to obtain new counsel. Retained counsel stated that he

had procured a plea deal with the State that involved an 11-year aggregate sentence in

exchange for Tate pleading guilty to three offenses, but that Tate was not satisfied with

this deal. Retained counsel asked the trial court to allow Tate to obtain new counsel.

{¶7} In response to questions from the court, Tate stated that an 11-year

sentence was “too much time.” The court told Tate that he faced a potential sentence

of at least 39 years of imprisonment, and that an 11-year sentence was a good deal.

Tate told the court that the attorney who had represented him before retained counsel

had “offered me 5 max, 3 minimum.” In response, retained counsel requested a

competency evaluation of Tate because Tate’s prior counsel had Tate convinced that

he was “looking at 3 to 5, maybe 7.” The trial court issued an entry appointing the court

4 OHIO FIRST DISTRICT COURT OF APPEALS

clinic forensic services to examine Tate, and the case was continued for a competency

hearing. The court stated that retained counsel was to remain as counsel for Tate until

the competency report was obtained.

{¶8} In September 2022, Tate filed additional pro se motions. First, he filed

a motion to reduce his bond from $500,000 straight to $50,000 at ten percent.

Second, he filed an “affidavit of facts.” As relevant to this appeal, this document stated

that he had fired his counsel, who was ineffective, and it demanded a refund of the

money that he had paid counsel. The motion further asked that the charges against

him be dismissed because “the 270 day limit to be brought to trail [sic] has expired.”

Third, Tate filed a motion to “remove counsel” because counsel was ineffective. In

support, Tate contended that counsel was unreachable by phone to discuss a defense

and that counsel had only met with Tate two times since he was incarcerated in

February 2022.

{¶9} An entry of continuance was issued in October 2022, reflecting that

retained counsel planned to hire a doctor to obtain a second opinion on Tate’s

competency. Four additional continuances were issued at Tate’s request, all providing

that the matter was continued for a competency report or hearing.

{¶10} On January 19, 2023, the trial court issued an entry finding Tate

competent to stand trial. At a hearing on that date, the court stated that a second

competency opinion had not been obtained. With respect to Tate’s competency,

retained counsel represented, “I’ve had conversations with Mr. Tate. His mental

competency fluctuates. Sometimes I can speak and discuss the matter with Mr. Tate,

and we’ll have a lucid, intelligible conversation about the facts and evidence; and on

other occasions I don’t believe that he is understanding and comprehending my

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