State v. Tolbert

Ohio Court of Appeals·Decided September 3, 2026·No. 115545; 115546; 115547·Published

Opinion

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellant, :

Nos. 115545, 115546,

v. : and 115547

ANTOINE TOLBERT, ET AL., :

Defendants-Appellees. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED

RELEASED AND JOURNALIZED: September 3, 2026

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case Nos. CR-25-700220-A, CR-25-700220-B, and CR-25-700220-C

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Tasha L. Forchione and Michael R. Wajda, Assistant Prosecuting Attorneys, for appellant.

The Pattakos Law Firm LLC, Peter Pattakos, Gregory Gipson, and Zoran Balac, for appellees.

LISA B. FORBES, J.:

The State of Ohio appeals following the jury verdicts finding Antoine Tolbert (“Tolbert”), Rameer Askew (“Askew”), and Austreeia Everson (“Everson”) (collectively, “Appellees”) not guilty of various offenses. After a thorough review of the facts and the law, we sustain the State’s first assignment of error regarding the instructions submitted to the jury addressing qualified immunity for law enforcement. I. Procedural History A. The Charges On March 11, 2025, Appellees were named in a 13-count indictment in the Cuyahoga County Common Pleas Court. The indictment named Tolbert and Askew in Count 1, aggravated robbery, a first-degree felony, in violation of R.C. 2911.01(A)(1) and Count 2, kidnapping, a first-degree felony, in violation of R.C. 2905.01(A)(2).

Tolbert was named in Count 3, extortion, a third-degree felony, in violation of R.C. 2905.11(A)(3); Count 4, extortion, a third-degree felony, in violation of R.C. 2905.11(A)(5); Count 5, aggravated riot, a fourth-degree felony, in violation of R.C. 2917.02(A)(2); Count 6, aggravated riot, a fifth-degree felony, in violation of R.C. 2917.02(A)(3); Count 7, breaking and entering, a fifth-degree felony, in violation of R.C. 2911.13(B); Count 8, aggravated menacing, a first-degree misdemeanor, in violation of R.C. 2903.21(A); and Count 9, intimidation of an attorney, victim or witness in a criminal case, a third-degree felony, in violation of R.C. 2921.04(B)(1).1 Everson was named in Count 10, extortion, a third-degree felony, in violation of R.C. 2905.11(A)(3); Count 11, intimidation of an attorney, victim, or witness in a criminal case, a third-degree felony, in violation of R.C. 2921.04(B)(1); Count 12, intimidation of an attorney, victim, or witness in a criminal case, a first- degree misdemeanor, in violation of R.C. 2921.04(A); and Count 13, aggravated menacing, a first-degree misdemeanor, in violation of R.C. 2903.21(A).

B. Trial and Jury Instructions The case proceeded to a jury trial. Following testimony from 30 witnesses, including Tolbert, Askew, Everson, and more than ten law-enforcement officers, the case was submitted to the jury. Over the State’s objection, the trial court instructed the jury as follows:

The defendants in this case maintain that they’ve been charged in this case not for legitimate purposes, but because one or more of the State’s officers responsible for the decision to charge them has a motive to retaliate against them or is otherwise biased against them. The State strongly disagrees. Because one or more jurors might believe that police officers would tend not to pursue retaliatory or bias[ed] charges against citizens for fear of being held legally accountable for such conduct in a later civil lawsuit, you should be aware that police officers are protected by legal doctrines that may immunize them from civil lawsuits by citizens from biased or retaliatory conduct.

The law also prohibits citizens from pursuing civil claims against state officials in connection with the purs[uit] of criminal charges when the citizen is actually convicted of those charges. In considering whether

1 Counts 1 through 9 included one- and three-year firearm specifications under

R.C. 2941.141(A) and 2941.145(A), respectively. Counts 3 through 9 each included three weapons-forfeiture specifications under R.C. 2941.1417(A).

investigating police officers’ actions in investigating and pursuing the charges at issue in this case were motivated by bias or intent to retaliate against the defendants, you may consider that the law may substantially shield police officers from legal accountability for such alleged bias or retaliatory acts. Your primary focus, however, should be on the actual charges in this case and the evidence concerning each and in giving your absolutely fair and impartial consideration to whether the State has proved the guilt of any or all the defendants by evidence beyond a reasonable doubt.

C. Verdict, Motion for Leave to Appeal, and This Appeal The jury found Appellees not guilty on all offenses and specifications.

On September 9, 2025, the State filed with this court a motion for leave to appeal. The State sought this court’s review of two issues: first, whether the court erred in instructing the jury to consider law-enforcement immunity in its deliberations, and, second whether the court erred by instructing the jury that a guilty verdict for extortion, aggravated riot, breaking and entering, aggravated menacing, and intimidation of a victim required a finding that a defendant communicated true threats of violence under U.S. Const. Amend I.

This court addressed the State’s motion for leave to appeal via a journal entry dated October 30, 2025. The journal entry noted that this court “may review substantive rulings of law when it is presented with an underlying legal question that is capable of repetition yet evading review.” The State was granted leave to appeal the jury instruction regarding the immunity of law-enforcement officers. The State was denied leave to appeal the jury instructions concerning true threats of violence.

The State now raises the following assignments of error:

I. The trial court erred by instructing the jury to consider law-

enforcement qualified immunity in its deliberations, unduly influencing the jury to decide guilt based on irrelevant factors, as prohibited by State v. Group, 2002-Ohio-7247, ¶ 117-[1]18 and State v.

Scott, 26 Ohio St. 3d 92, 101 (1986).

II. The trial court erred by instructing the jury on First Amendment “true threat” principles, thereby submitting questions of constitutional law to the jury, mischaracterizing the nature of the charges, and imposing a heightened burden of proof not required by Ohio law.

II. Law and Analysis

A. Assignment of Error No. 1 — Jury Instructions Concerning Law-

Enforcement Officer Immunity

With its first assignment of error, the State asserts that the trial court erred by instructing the jury in this criminal matter about immunity doctrines that protect law-enforcement officers from liability for civil damages. We agree.

“A trial court must ‘[w]hen instructing the jury . . . provide “a plain, distinct, and unambiguous statement of the law applicable to the evidence.”’” State v. Elko, 2020-Ohio-4466, ¶ 29 (8th Dist.), quoting State v. Torres, 2013-Ohio-5030, ¶ 50 (8th Dist.), quoting State v. Driggins, 2012-Ohio-5287, ¶ 73 (8th Dist.). “‘A trial court’s decision to grant or deny a requested jury instruction is reviewed under an abuse of discretion standard.’” State v. Glass, 2025-Ohio-4670, ¶ 46 (8th Dist.), quoting State v. Hayes, 2024-Ohio-4679, ¶ 10 (8th Dist.). An abuse of discretion occurs when a court exercises “its judgment, in an unwarranted way, in regard to a matter over which it has discretionary authority.” Johnson v. Abdullah, 2021-Ohio- 3304, ¶ 35. An abuse of discretion “‘implies that the court’s attitude is unreasonable, arbitrary or unconscionable.’” W.A.F.P., Inc. v. Sky Fuel Inc., 2024-Ohio-3297, ¶ 13 (8th Dist.), quoting Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983).

The trial court abused its discretion by instructing the jury as it did.

Free access — add to your briefcase to read the full text and ask questions with AI

State v. Tolbert, (Ohio Ct. App. 2026).

State v. Tolbert (State v. Tolbert) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Evans v. Michigan
133 S. Ct. 1069 (Supreme Court, 2013)
State v. Group
2002 Ohio 7247 (Ohio Supreme Court, 2002)
State v. Torres
2013 Ohio 5030 (Ohio Court of Appeals, 2013)
State v. Driggins
2012 Ohio 5287 (Ohio Court of Appeals, 2012)
Curtis v. State
148 N.E. 831 (Ohio Supreme Court, 1925)
State v. Rac
2019 Ohio 893 (Ohio Court of Appeals, 2019)
State v. Ramirez (Slip Opinion)
2020 Ohio 602 (Ohio Supreme Court, 2020)
State v. Elko
2020 Ohio 4466 (Ohio Court of Appeals, 2020)
State v. Golsby
2020 Ohio 4651 (Ohio Court of Appeals, 2020)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
State v. Scott
497 N.E.2d 55 (Ohio Supreme Court, 1986)
State v. Bistricky
555 N.E.2d 644 (Ohio Supreme Court, 1990)
Cleveland v. Graham
2024 Ohio 336 (Ohio Court of Appeals, 2024)
W.A.F.P., Inc. v. Sky Fuel, Inc.
2024 Ohio 3297 (Ohio Court of Appeals, 2024)
State v. Glass
2025 Ohio 4670 (Ohio Court of Appeals, 2025)
State v. Jones
2025 Ohio 5389 (Ohio Supreme Court, 2025)
Nelsonville v. Nguyen
2026 Ohio 1699 (Ohio Court of Appeals, 2026)