State v. Vanhorn

2025 Ohio 5748
CourtOhio Court of Appeals
DecidedDecember 23, 2025
Docket25 CAA 07 0052
StatusPublished

This text of 2025 Ohio 5748 (State v. Vanhorn) 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. Vanhorn, 2025 Ohio 5748 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Vanhorn, 2025-Ohio-5748.]

COURT OF APPEALS DELAWARE COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO, Case No. 25 CAA 07 0052

Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Delaware County Court of Common Pleas, Case No. 11 CRI 12 0623 DEREK VANHORN, Judgment: Affirmed Defendant – Appellant Date of Judgment Entry: December 23, 2025

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

APPEARANCES: MELISSA A. SCHIFFEL and KATHERYN L. MUNGER, for Plaintiff- Appellee; RICHARD PIATT, for Defendant-Appellant.

Montgomery, J.

STATEMENT OF FACTS AND THE CASE

{¶1} Appellant Derek Vanhorn (hereinafter “Vanhorn”) was driving at a high rate

of speed with a suspended license on August 10, 2011, when his car went left of center

and struck another vehicle, killing its passenger. Vanhorn had a history of extensive traffic

offenses and stated he may have been texting at the time of the accident.

{¶2} Vanhorn was charged with Aggravated Vehicular Homicide in violation of

R.C. 2903.06(A)(2)(a) on December 2, 2011, in the Delaware County Court of Common

Pleas. Vanhorn pled “no contest” on April 11, 2012, and the trial court found him guilty on

the same date. Judgment Entry on No Contest Plea 4/13/12, p. 3. {¶3} A sentencing hearing was held on June 12, 2012, wherein Vanhorn was

sentenced to 42 months in prison, ordered to pay court costs and restitution and his

driver’s license was suspended for life. Judgment Entry on Sentence 6/15/12, p. 2.

{¶4} After his release from incarceration, Vanhorn filed a Motion for Limited

Driving Privileges in the Common Pleas Court of Delaware County on July 30, 2015

(hereinafter referred to as “7/30/15 Motion”). The trial court issued a Judgment Entry

Addressing the Defendant’s 7/30/15 Request for Limited Driving Privileges on August 7,

2015 (hereinafter referred to as “8/7/15 Entry”) wherein Judge Gormley, one of the judges

of the Delaware County Court of Common Pleas, stated, “Before I will consider granting

those privileges, though, the defendant must satisfy the reinstatement requirements set

by the Ohio Bureau of Motor Vehicles (BMV) for various other suspensions that are on

his traffic record.” 8/7/15 Entry, p. 1.

{¶5} The trial court’s 8/7/15 Entry granted Vanhorn permission to renew his

driver’s license. The Entry also stated eight requirements Vanhorn must complete before

Judge Gormley would, “consider granting driving privileges to him.” Id., p. 2.

{¶6} Ten years after the aforementioned trial court’s judgment entry, Vanhorn

filed a Motion on June 3, 2025 (hereinafter referred to as “6/3/25 Motion”) in the trial court

seeking an order permitting him to complete a remedial driving course and/or take his

driver’s license examination.

{¶7} The State of Ohio filed a Reply to Defendant’s Motion on June 4, 2025

(hereinafter referred to as “State’s Reply”), opposing Vanhorn’s 6/3/25 Motion.

{¶8} Judge Marianne T. Hemmeter, a trial judge in the Delaware County Court

of Common Pleas, issued a Judgment Entry Denying Defendant’s Request for an Order Allowing Him to Retest For his Driver’s License (hereinafter referred to as “6/6/25 Entry”)

on June 6, 2025.

{¶9} Vanhorn appealed the trial court’s 6/6/25 Entry and asserts the following

assignments of error:

{¶10} “I. THE TRIAL COURT ERRED BY DENYING DEFENDANT-

APPELLANT’S MOTION ALLOWING HIM TO RETEST IN AN EFFORT TO OBTAIN A

VALID OHIO DRIVER’S LICENSE AS THERE WAS A VALID JUDGEMENT [SIC]

ENTRY IN AFFECT [SIC] ALLOWING HIM TO DO SO.”

{¶11} “II. THE TRIAL COURT ERRED BY DENYING DEFENDANT-

APPELLANT’S MOTION ALLOWING HIM TO RETEST TO OBTAIN A VALID OHIO

DRIVER’S LICENSE, AND THE DENIAL OF DEFENDANT-APPELLANT’S MOTION

WAS AN ABUSE OF DISCRETION.”

STANDARD OF REVIEW

{¶12} This Court will review the decision of the trial court under an abuse of

discretion standard. “Abuse of Discretion” has been defined by the Ohio Supreme Court

as “conduct that is unreasonable, arbitrary, or unconscionable.” Blakemore v Blakemore,

5 Ohio St.3d 217, 219 (1983).

ANALYSIS

{¶13} Vanhorn argues in his first assignment of error that the trial court erred by

denying his motion for an order that would allow him to retest for his driver’s license.

{¶14} Vanhorn argues in his second assignment of error that the trial court’s denial

of his motion filed on June 3, 2025, was an abuse of discretion.

{¶15} Vanhorn’s arguments will be addressed together. {¶16} As a general rule, courts follow the law of the case doctrine. Said rule has

been defined as, “The rule of the law of the case is a rule of practice, based upon sound

policy that when an issue is once litigated and decided, that should be the end of the

matter." United States v. United States Smelting Ref. & Mining Co., 339 U.S. 186, 198

(1950).

{¶17} This Court has found, “The doctrine's purpose is to ensure ‘consistency of

results in a case, to avoid endless litigation by settling the issues, and to preserve the

structure of superior and inferior courts as designed by the Ohio Constitution.’ ” Myers v.

Vitanovic, 2022-Ohio-4802, ¶ 18, citing Nolan, at 3, 462 N.E.2d 410. The Myers’ court

went on to say, “The doctrine ‘should not be taken to imply that a trial court can

never, under any circumstances, reconsider its prior ruling.’ " Id., citing Poluse v.

Youngstown, 135 Ohio App.3d 720, 725 (7th Dist. 1999).

{¶18} This Court ruled in Myers, “We find that the trial court did not err in failing to

apply the law of the case doctrine and was within its discretion to review the facts and

evidence submitted at the time of the hearing to determine appellant's income for

purposes of child support.” Id., at ¶ 19.

{¶19} Vanhorn argues that the trial court “lacked the authority to reconsider its

own valid judgement [sic]”. Appellant Brief, p. 5.

{¶20} Since the trial court imposed its sentence on April 11, 2012, Vanhorn has

filed two separate motions with the trial court regarding the lifetime suspension of his

driving privileges.

{¶21} Judge Gormley considered Vanhorn’s 7/30/15 Motion and issued the trial

court’s 8/7/15 Entry that granted him permission to renew his driver’s license. {¶22} Ten years later, Judge Hemmeter considered Vanhorn’s 6/3/25 Motion and

issued the trial court’s 6/6/25 Entry that denied Vanhorn’s request for an up-to-date order

to provide to the BMV to allow him to retest.

{¶23} Ten years passed between the filing of Vanhorn’s two motions. Vanhorn

incurred one criminal conviction and one traffic conviction during this time.

{¶24} Vanhorn was convicted of F3 failure to comply in Washington County, Ohio

in 2019 when he fled from law enforcement. Vanhorn also operated a vehicle without a

license on October 1, 2023, and was convicted of driving under suspension and physical

control. State’s Reply, p. 2.

{¶25} The trial court was within its discretion to review the facts and evidence submitted

at the time of the filing of each of Vanhorn’s motions. The trial court in the case sub judice

considered Vanhorn’s recent convictions and denied Vanhorn’s 6/3/25 Motion.

{¶26} The trial court did not abuse its discretion when it denied Vanhorn’s 6/3/25

Motion.

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Related

Poluse v. City of Youngstown
735 N.E.2d 505 (Ohio Court of Appeals, 1999)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
Nolan v. Nolan
462 N.E.2d 410 (Ohio Supreme Court, 1984)
Myers v. Vitanovic
2022 Ohio 4802 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5748, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-vanhorn-ohioctapp-2025.