State v. Thaler

2025 Ohio 2818
CourtOhio Court of Appeals
DecidedAugust 7, 2025
Docket24AP0011
StatusPublished

This text of 2025 Ohio 2818 (State v. Thaler) 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. Thaler, 2025 Ohio 2818 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Thaler, 2025-Ohio-2818.]

COURT OF APPEALS MORGAN COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO, : JUDGES: : Hon. William B. Hoffman, P.J. Plaintiff - Appellee : Hon. Robert G. Montgomery, J. : Hon. Andrew J. King, J. -vs- : : JAMES THALER, : Case No. 24AP0011 : Defendant - Appellant : OPINION

CHARACTER OF PROCEEDING: Appeal from the Morgan County Court of Common Pleas, Case No. 24CR0006

JUDGMENT: Affirmed

DATE OF JUDGMENT: August 7, 2025

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

RICHARD D. WELCH BRIAN W. BENBOW Morgan County Prosecuting Attorney Benbow Law Offices LLC 19 E. Main Street 265 Sunrise Center Drive McConnelsville, OH 43756 Zanesville, OH 43701 Montgomery, J.

{¶1} This matter comes before the Court upon the Motion to Withdraw and

Anders brief filed by Attorney Brian Benbow, appellate counsel for Defendant-Appellant,

James Thaler (“Appellant”). After Appellant pled guilty to strangulation, Appellant was

convicted and sentenced to 12 months imprisonment. Appellate counsel has filed a brief

pursuant to Anders v. California, 386 U.S. 738 (1967).

FACTS AND PROCEDURAL HISTORY

{¶2} Appellant was indicted by the Morgan County Grand Jury with F5

strangulation in violation of R.C. 2903.18(B)(3). Appellant initially pled not guilty but later

decided to change his plea. On June 26, 2024, a change of plea hearing took place

wherein Appellant was represented by counsel and the court conducted its Crim. R 11

colloquy. Prior to the plea hearing, Appellant executed a written plea of guilty and waiver

of rights/notification forms after reviewing said forms with counsel. On September 16,

2024, a sentencing hearing took place and the trial court sentenced Appellant to twelve

months incarceration. The sentence imposed was a maximum sentence, despite there

being a Joint Sentencing Recommendation of five years community control. The trial

court stated it imposed the maximum due to Appellant’s extensive criminal record,

including a prior felony conviction and a misdemeanor offense of violence in the prior two

years. The trial court informed Appellant directly at both the plea hearing and the

sentencing hearing that it was not bound by the Joint Sentencing Recommendation.

Appellant understood this fact at the plea hearing and proceeded with his guilty plea.

{¶3} Appellate counsel filed a brief pursuant to Anders v. California, 386 U.S.

738 (1967), and sets forth the following “potential” assignments of error: {¶4} “I. THE COURT ERRED IN IMPOSING A SENTENCE THAT WAS GROSSLY DISPROPORTIONATE TO APPELLANT'S CONDUCT AND NOT IN ACCORDANCE WITH STATUTES GOVERNING FELONY SENTENCING AND WHICH SENTENCE DEMONSTRATES [AN] UNNECESSARY BURDEN ON STATE RESOURCES.”

{¶5} “II. THE TRIAL COURT ERRED BY IMPOSING MAXIMUM CONSECUTIVE SENTENCES, WHICH SENTENCE WAS GREATER THAN AGREED UPON BY THE PARTIES IN BREACH OF THE PRIOR PLEA AGREEMENT.”

{¶6} “III. THE TRIAL COURT ERRED BY NOT CONTINUING THE SENTENCING HEARING WHEN THE STATE OF OHIO ASKED THE COURT FOR A MAXIMUM CONSECUTIVE SENTENCE IN VIOLATION OF THE PRIOR PLEA AGREEMENT.”

{¶7} “IV. APPELLANT WAS DENIED HIS CONSTITUTIONAL RIGHT TO EFFECTIVE ASSISTANCE OF COUNSEL PURSUANT TO STRICKLAND V. WASHINGTON, 466 U.S. 668 (1984).”

{¶8} The Motion to Withdraw and Anders Brief, states that counsel has reviewed

the entire record, researched potential issues, and determined that there were no

meritorious issues for review which would support an appeal. Attorney Benbow requests

that this Court make an independent review of the record to determine whether there are

any additional issues that would support an appeal.

Standard of Review - Anders v. California

{¶9} In Anders, the United States Supreme Court held if, after a conscientious

examination of the record, a defendant's counsel concludes the case is wholly frivolous,

then he should so advise the court and request permission to withdraw. Anders v.

California, 386 U.S. 738, 744 (1967). Counsel must accompany his request with a brief

identifying anything in the record that could arguably support his client's appeal. Id.

Counsel must also: (1) furnish his client with a copy of the brief and request to withdraw;

and (2) allow his client sufficient time to raise any matters that the client chooses. Id. Once

the defendant's counsel satisfies these requirements, the appellate court must fully examine the proceedings below to determine if any arguably meritorious issues exist. If

the appellate court also determines that the appeal is wholly frivolous, it may grant

counsel's request to withdraw and dismiss the appeal without violating constitutional

requirements or may proceed to a decision on the merits if state law so requires. Id.

{¶10} By Judgment Entry filed March 10, 2025, this Court indicated that it had

received notice pursuant to Anders that Attorney Benbow provided Appellant a copy of

the Anders appeal brief. In that same Judgment Entry, this Court informed Appellant he

may file a pro se brief in support of the appeal within 30 days from the date of the Entry.

Neither the State of Ohio nor Appellant has filed any brief in Response to counsel’s

Anders brief.

{¶11} The record establishes that Appellant’s counsel satisfied Anders

requirements. Accordingly, we proceed to review the potential assignments of error to

determine if any arguably meritorious issues exist, keeping in mind that,

Anders equates a frivolous appeal with one that presents issues lacking in

arguable merit. An issue is not lacking in that regard merely because the

prosecution can be expected to present a strong argument in reply. An issue

lacks arguable merit if, on the facts and law involved, no responsible

contention can be made that it offers a basis for reversal.

State v. Pullen, 2002-Ohio-6788, ¶ 4 (2d Dist.); State v. Moore, 2009-Ohio-1416, ¶ 4 (2d

Dist.); State v. Grant, 2023-Ohio-4614, ¶ 11 (5th Dist.); State v. Reynolds, 2024-Ohio-

1956, ¶ 10 (5th Dist.). First, Second, and Third Potential Assignments of Error

{¶12} Although appellate counsel acknowledges that: (1) the trial court complied

or substantially complied with Crim. R. 11 in accepting Appellant’s guilty plea; (2) the trial

court clearly informed Appellant at the plea hearing and at sentencing that it did not have

to accept the parties’ joint recommendation regarding sentence; and (3) the sentence

imposed is within the statutory guidelines - counsel asserts three potential assignments

of error related to the sentence imposed. Because all three potential assignments of error

are interrelated, we address them together.

{¶13} In accordance with R.C. 2953.08(A)(1), Appellant is entitled to appeal the

maximum sentence imposed on his conviction. A court reviewing a criminal sentence is

required by R.C. 2953.08(F) to review the entire trial court record, including any oral or

written statements and presentence investigation reports. R.C. 2953.08(F)(1) through (4).

We review felony sentences using the standard of review set forth in R.C. 2953.08. State

v. Marcum, 2016-Ohio-1002, ¶ 22; State v. Howell, 2015-Ohio-4049, ¶ 31 (5th Dist.).

Pursuant to R.C.

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Related

Michel v. Louisiana
350 U.S. 91 (Supreme Court, 1956)
MacHibroda v. United States
368 U.S. 487 (Supreme Court, 1962)
Anders v. California
386 U.S. 738 (Supreme Court, 1967)
North Carolina v. Butler
441 U.S. 369 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
United States v. Broce
488 U.S. 563 (Supreme Court, 1989)
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2014 Ohio 3177 (Ohio Supreme Court, 2014)
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State v. Marcum (Slip Opinion)
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State v. Groves
2019 Ohio 5025 (Ohio Court of Appeals, 2019)
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2021 Ohio 1512 (Ohio Court of Appeals, 2021)
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2022 Ohio 1212 (Ohio Court of Appeals, 2022)
State v. Stewart
364 N.E.2d 1163 (Ohio Supreme Court, 1977)
State v. Ballard
423 N.E.2d 115 (Ohio Supreme Court, 1981)
State v. Clark
527 N.E.2d 844 (Ohio Supreme Court, 1988)
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2025 Ohio 2818, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-thaler-ohioctapp-2025.