State v. Thorpe

2026 Ohio 412
CourtOhio Court of Appeals
DecidedFebruary 6, 2026
DocketCT2025-0070
StatusPublished

This text of 2026 Ohio 412 (State v. Thorpe) 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. Thorpe, 2026 Ohio 412 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Thorpe, 2026-Ohio-412.]

COURT OF APPEALS MUSKINGUM COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO, Case No. CT2025-0070

Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Muskingum County Court of Common Pleas, Case No. CR2025-0312 DUSTIN O. THORPE, Judgment: Affirmed Defendant – Appellant Date of Judgment Entry: February 6, 2026

BEFORE: Andrew J. King; Robert G. Montgomery; Kevin W. Popham, Judges

APPEARANCES: JOSEPH A. PALMER, for Plaintiff-Appellee; APRIL F. CAMPBELL, for Defendant-Appellant.

Montgomery, J.

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

Anders brief filed by Attorney April Campbell, appointed appellate counsel for Defendant-

Appellant, Dustin Thorpe (“Appellant”). After timely filing the notice of appeal, appellate

counsel filed the instant Motion and brief pursuant to Anders v. California, 386 U.S. 738

(1967).

STATEMENT OF THE CASE AND RELEVANT FACTS

{¶2} Appellant is currently serving an aggregate prison term of 12 years after he

pled guilty to four (4) felonies and one gun specification. The charges arose from a drug task force’s use of a confidential informant who purchased approximately one ounce of

methamphetamines from Appellant on two separate occasions (30 grams one day; 26.6

grams the other day). The task force obtained a warrant to search Appellant’s home.

The search revealed an additional 4.6 grams of methamphetamines, six guns, scales and

pipes and $3,250.00 in cash. Appellant confessed to trafficking methamphetamines.

{¶3} The State and Appellant negotiated a plea deal and Appellant pled guilty to

two second-degree felony drug trafficking offenses, one third-degree felony possession

of drugs with a one-year firearm specification, and one count of weapons while under

disability. In exchange, the State dismissed the remaining nine (9) counts in the

indictment. It also dismissed the firearm specifications, except the one referenced. The

State reserved the right to argue an appropriate sentence. On August 19, 2025, a change

of plea hearing was held. The court detailed the offenses and possible penalties for each

and Appellant stated he understood and went forward with his pleas. Change of Plea Tr.,

at pp. 6-11. That same day, the court proceeded to sentence Appellant. The State

requested a fifteen-year prison term while Appellant argued for something closer to the

minimum. Ultimately, the court imposed a 12-year aggregate sentence, nine years being

mandatory.

{¶4} Although Appellant timely filed an appeal to this Court, Appellant’s court-

appointed counsel later filed the instant brief pursuant to Anders v. California, 386 U.S.

738 (1967) and a corresponding Motion to Withdraw. The Motion to Withdraw and Anders

Brief state that counsel has reviewed the entire record, researched potential issues, and

determined that there are no non-frivolous issues to support an appeal. Attorney

Campbell states the record demonstrates Appellant’s guilty pleas were knowing, intelligent, and voluntary and that his sentences are not contrary to law. Attorney

Campbell 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

{¶5} 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. The

Anders procedure “permit[s] appellate counsel to represent an indigent client and yet

avoid the ethical pitfall of filing a frivolous appeal.” State v. Tsibouris, 2013-Ohio-3324, ¶

4 (1st Dist.). Thus, a defendant's right to appeal does not include a frivolous appeal.

State v. Taylor, 2015-Ohio-420 ¶ 4 (8th Dist.), citing Penson v. Ohio, 488 U.S. 75, 83-84

(1988).

{¶6} The Anders procedure is designed for cases in which “counsel finds [the]

case to be wholly frivolous, after a conscientious examination” of the record. Anders, at

744. Accordingly, a comprehensive review of the record is a fundamental first step.

“Counsel cannot conclude an appeal is frivolous without first conducting a detailed review

of the case.” Tsibouris, at ¶ 6. This detailed review must include a complete review of the

case, including all transcripts. See Tsibouris; In re A.J.F., 2018-Ohio-1208, ¶¶ 22-24 (11th

Dist.).

{¶7} 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. Anders, at 744. Once 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.

{¶8} By Judgment Entry filed October 9, 2025, this Court indicated that it had

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

the Anders brief. In that same Judgment Entry, we informed Appellant he may file a pro

se brief in support of the appeal within 60 days from the date of the Entry. Appellant has

not filed anything to date.

{¶9} 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.

{¶10} 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.).

POTENTIAL ASSIGNMENT OF ERROR

{¶11} “I. THE TRIAL COURT ERRED IN ACCEPTING THORPE’S GUILTY PLEAS UNDER CRIM.R. 11 AND ERRED IN SENTENCING THORPE.” Guilty Plea

{¶12} When reviewing a plea’s compliance with Criminal Rule 11(C), we apply a

de novo standard of review. State v. Nero, 56 Ohio St.3d 106, 108-109 (1990); State v.

Lebron, 2020-Ohio-1507, ¶ 9 (8th Dist.); State v. Groves, 2019-Ohio-5025, ¶ 7 (5th Dist.).

This Court has stated:

The entry of a guilty plea is a grave decision by an accused to dispense with

a trial and allow the state to obtain a conviction without following the

otherwise difficult process of proving his guilt beyond a reasonable doubt.

See Machibroda v.

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Related

MacHibroda v. United States
368 U.S. 487 (Supreme Court, 1962)
Anders v. California
386 U.S. 738 (Supreme Court, 1967)
Penson v. Ohio
488 U.S. 75 (Supreme Court, 1988)
United States v. Broce
488 U.S. 563 (Supreme Court, 1989)
State v. Bonnell (Slip Opinion)
2014 Ohio 3177 (Ohio Supreme Court, 2014)
State v. Tsibouris
2013 Ohio 3324 (Ohio Court of Appeals, 2013)
State v. Hodges
2013 Ohio 5025 (Ohio Court of Appeals, 2013)
State v. Taylor
2015 Ohio 420 (Ohio Court of Appeals, 2015)
State v. Howell
2015 Ohio 4049 (Ohio Court of Appeals, 2015)
In re A.J.F.
2018 Ohio 1208 (Ohio Court of Appeals, 2018)
State v. Groves
2019 Ohio 5025 (Ohio Court of Appeals, 2019)
State v. McMillen
2022 Ohio 1212 (Ohio Court of Appeals, 2022)
State v. Nero
564 N.E.2d 474 (Ohio Supreme Court, 1990)
State v. Grant
2023 Ohio 4614 (Ohio Court of Appeals, 2023)
State v. Reynolds
2024 Ohio 1956 (Ohio Court of Appeals, 2024)
State v. Hinkle
2024 Ohio 5499 (Ohio Court of Appeals, 2024)

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2026 Ohio 412, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-thorpe-ohioctapp-2026.