State v. Vohs

2025 Ohio 1107
CourtOhio Court of Appeals
DecidedMarch 28, 2025
Docket2024CA0020
StatusPublished

This text of 2025 Ohio 1107 (State v. Vohs) 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. Vohs, 2025 Ohio 1107 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Vohs, 2025-Ohio-1107.]

COURT OF APPEALS COSHOCTON COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO : JUDGES: : Hon. Craig R. Baldwin, P.J. Plaintiff - Appellee : Hon. Robert G. Montgomery, J. : Hon. David M. Gormley, J. -vs- : : MARK A. VOHS : Case No. 2024CA0020 : Defendant - Appellant : OPINION

CHARACTER OF PROCEEDING: Appeal from the Coshocton County Court of Common Pleas, Case No. 2024 CR 0002

JUDGMENT: Affirmed

DATE OF JUDGMENT: March 28, 2025

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

BENJAMIN E. HALL TODD W. BARSTOW Coshocton County Prosecuting Attorney 14 North Park Place 500 North 3rd Street,, Suite A Newark, Ohio 43055 Coshocton, Ohio 43812 Gormley, J.

{¶1} Defendant Mark A. Vohs pled guilty in Coshocton County to a second-

degree-felony charge of aggravated possession of drugs, and he was sentenced to an

indefinite prison term with a minimum length of six years and a maximum length of nine

years. A prison term of that length had been jointly recommended to the trial court by the

parties as part of their plea agreement. Vohs’s untimely appeal was allowed by this court.

We now affirm.

Facts and Procedural History

{¶2} Vohs was indicted in January 2024 on one count of aggravated possession

of drugs, a felony of the second degree. Even though Vohs was represented by appointed

counsel, he acted pro se in filing a motion to suppress. The trial court did not consider

that motion because it was not filed by counsel, and Vohs’s counsel in fact moved to

withdraw the motion at the outset of the change-of-plea hearing.

{¶3} In August 2024, Vohs and the prosecution reached a plea agreement that

called for Vohs to plead guilty to the charge, and the parties jointly recommended that a

prison term of six to nine years be imposed. The trial court accepted Vohs’s plea and

imposed the recommended sentence.

{¶4} The trial judge held the plea-change hearing on the record in accordance

with Criminal Rule 22, and the judge also conducted the hearing in the way that Criminal

Rule 11(C) requires, ensuring that Vohs was entering his guilty plea voluntarily, that he

understood the nature of the criminal charge, that he understood the maximum penalties,

that he understood the effect of a guilty plea, and that he understood that the immediate

imposition of a sentence was possible. The trial judge thoroughly addressed, as well, the constitutional rights spelled out in Criminal Rule 22(C)(2)(c), and Vohs expressed on the

record not only his understanding of each of those rights but also his desire to waive

them. Vohs himself, along with counsel for both parties, signed a written plea of guilty,

and that document was promptly filed in the clerk’s office in Coshocton County.

{¶5} Once the trial judge accepted Vohs’s guilty plea and made a guilty finding

on the plea, the parties agreed that no presentence investigation was needed and that

they were ready for the judge to impose a sentence. The judge accommodated that

request and, after affording the parties an opportunity to be heard in accordance with

Criminal Rule 32(A), he imposed the very sentence that the parties had jointly

recommended: an indefinite prison term of six to nine years for the second-degree-felony

aggravated-possession-of-drugs charge. The judge explained to Vohs that the minimum

prison term was six years and the maximum term was nine years, and that the minimum

prison term of six years was mandatory. The judge then granted Vohs 166 days of jail-

time credit, and Vohs’s counsel stated that he had no objection to the trial judge’s finding

on that issue.

{¶6} Soon thereafter, Vohs filed an untimely notice of appeal, and new counsel

was appointed to represent him here. This court granted counsel’s motion to file a

delayed appeal.

{¶7} Once the record for this appeal was transmitted, Vohs’s appellate counsel

filed his appellate brief here. In that brief, Vohs’s counsel, in accordance with Anders v.

California, 386 U.S. 738 (1967), indicates that no colorable issues exist that might prompt

this court to overturn Vohs’s conviction and sentence. The appellate lawyer also indicated in the brief that he had provided copies of it to both Vohs himself and to the prosecutor.

Appellate counsel also moved to withdraw as counsel in the case.

{¶8} This court then sent a notice to the parties indicating that Vohs could file his

own appellate brief and the State could of course respond to any such brief and to the

Anders brief. The State filed a brief, but Vohs did not file his own brief.

Our Review of the Record Supports the View of Vohs’s Counsel: This Appeal Is Frivolous

{¶9} Under Anders, court-appointed appellate counsel in a criminal case is

permitted to indicate — after the attorney has conscientiously reviewed the full record —

that any possible grounds for an appeal in the case appear to be frivolous. See id. at

744. When such a brief is filed, Anders instructs counsel to file a brief identifying anything

in the record that might arguably support the appeal. See State v. Sergent, 2016-Ohio-

2696, ¶ 8, fn.1. The court of appeals should then ensure that the indigent defendant

receives a copy of that brief and should give the defendant an opportunity to raise any

arguments that he or she would like to present in the appeal. Anders at 744. And then

finally, the court itself should fully examine the case record to determine whether the

appeal is frivolous. Id.

{¶10} All of those steps have occurred in this appeal. Though the Anders brief

filed by Vohs’s appellate counsel in fact indicates that that lawyer could find no issues

that might arguably support the appeal, we have undertaken our duty to independently

examine the record to determine whether the appeal is frivolous. We find that it is.

A. The Guilty-Plea Hearing Was Properly Conducted

{¶11} The trial judge properly conducted the plea-change hearing in this felony

case on the record, and he addressed at that hearing the constitutional rights that must be discussed, the nature of the charge, the maximum penalties, the effect of a guilty plea,

and the possibility of an immediate sentence. The trial judge’s colloquy with the defendant

demonstrates, too, that the defendant entered his guilty plea knowingly and voluntarily

and with a full understanding of his rights and of the implications of the plea change. The

judge even took a brief recess during the hearing to allow Vohs to consult with his counsel

about whether he would be entitled to a reduction of the minimum term of his sentence

for “good days” while incarcerated. When the hearing resumed, the judge ensured that

Vohs understood that he was subject to a mandatory six-year term of incarceration and

that he was not eligible for any reduction of that sentence. Vohs indicated to the trial

judge that he was satisfied with the work that his attorney had done in the case.

{¶12} Vohs signed a plea of guilty during the hearing. The written plea was also

signed by Vohs’s counsel, the prosecutor, and the trial judge. That plea document was

filed in the trial court on the same afternoon as the hearing.

{¶13} In short, the plea fully comported with Ohio law. See State v. Veney, 2008-

Ohio-5200, ¶ 8 (“Crim.R. 11(C) governs the process that a trial court must use before

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
State v. Underwood
2010 Ohio 1 (Ohio Supreme Court, 2010)
State v. Owens
2016 Ohio 1203 (Ohio Court of Appeals, 2016)
State v. Engle
660 N.E.2d 450 (Ohio Supreme Court, 1996)

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Bluebook (online)
2025 Ohio 1107, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-vohs-ohioctapp-2025.