State v. Walker

2026 Ohio 51
CourtOhio Court of Appeals
DecidedJanuary 9, 2026
DocketC-250511
StatusPublished

This text of 2026 Ohio 51 (State v. Walker) 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. Walker, 2026 Ohio 51 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Walker, 2026-Ohio-51.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250511 TRIAL NO. 25/CRB/12608 Plaintiff-Appellee, :

vs. : JUDGMENT ENTRY MYRON WALKER, :

Defendant-Appellant. :

This cause was heard upon the appeal, the record, and the briefs. For the reasons set forth in the Opinion filed this date, the sentence is reversed in part and the cause is remanded. Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed under App.R. 24. The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk: Enter upon the journal of the court on 1/9/2026 per order of the court.

By:_______________________ Administrative Judge [Cite as State v. Walker, 2026-Ohio-51.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250511 TRIAL NO. 25/CRB/12608 Plaintiff-Appellee, :

vs. : OPINION MYRON WALKER, :

Criminal Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Sentence Reversed in Part and Cause Remanded

Date of Judgment Entry on Appeal: January 9, 2026

Emily Smart Woerner, City Solicitor, Susan Zurface, Chief Prosecuting Attorney, and Keith C. Forman, Supervising Prosecuting Attorney, for Plaintiff-Appellee,

Raymond T. Faller, Hamilton County Public Defender, and Lora Peters, Assistant Public Defender, for Defendant-Appellant. [Cite as State v. Walker, 2026-Ohio-51.]

BOCK, Judge.

{¶1} In a case related to the one on appeal, defendant-appellant Myron

Walker was convicted of attempted burglary, a felony offense. The trial court

sentenced him to a 30-month prison term. In the case on appeal, the trial court

convicted Walker of misdemeanor assault and imposed a 180-day jail term. It ordered

Walker to serve the 180-day jail term consecutively to the 30-month prison term in

the felony case.

{¶2} On appeal, Walker argues that the trial court abused its discretion

because under R.C. 2929.41, it lacked authority to order him to serve the misdemeanor

and felony sentences consecutively. The State concedes the error.

{¶3} We agree that the trial court abused its discretion by ordering Walker’s

misdemeanor sentence to be served consecutively to the felony sentence. Under

Supreme Court of Ohio precedent, absent an exception provided by R.C. 2929.41(B),

trial courts are required to impose concurrent sentences for felony and misdemeanor

convictions. State v. Polus, 2016-Ohio-655, ¶ 10. We therefore reverse the consecutive

nature of the sentence imposed for the misdemeanor assault charge and remand the

case for resentencing consistent with this opinion.

I. Factual and Procedural History

{¶4} In September 2025, Walker entered a no contest plea to misdemeanor

assault in violation of R.C. 2903.13. After the State read the facts, the court accepted

Walker’s plea, found him guilty of the offense, and turned to sentencing. Defense

counsel informed the trial court that in a related felony case, another trial court had

convicted Walker on an attempted-burglary charge and had imposed a 30-month term

in the Ohio Department of Rehabilitation and Correction.

{¶5} Walker’s counsel asked the trial court to impose only time served in the OHIO FIRST DISTRICT COURT OF APPEALS

assault case—16 days—in view of Walker’s felony sentence. The trial court sentenced

Walker to a 180-day jail term, to be served consecutively to the 30-month felony

sentence, with credit for 16 days served, along with a fine and court costs.

{¶6} On appeal, Walker argues that the trial court abused its discretion in

ordering his sentence in the misdemeanor assault case to be served consecutively to

the 30-month prison sentence in the felony attempted-burglary case. He asserts that

the trial court’s imposition of a consecutive sentence was not authorized by statute.

II. Analysis

A. R.C. 2929.41’s Language

{¶7} R.C. 2929.41(A) governs concurrent and consecutive sentences when a

trial court orders multiple sentences. The statute provides that

(A) Except as provided in division (B) of this section, . . . a prison

term, jail term, or sentence of imprisonment shall be served

concurrently with any other prison term, jail term, or sentence of

imprisonment imposed by a court of this state, another state, or the

United States. Except as provided in division (B)(3) of this section, a

jail term or sentence of imprisonment for [a] misdemeanor shall be

served concurrently with a prison term or sentence of imprisonment

for [a] felony served in a state or federal correctional institution.

(Emphasis added.)

{¶8} R.C. 2929.41(B) delineates the exceptions to this concurrent sentencing

presumption. Subsection (B)(1) provides,

A jail term or sentence of imprisonment for a misdemeanor shall be

served consecutively to any other prison term, jail term, or sentence of

imprisonment when the trial court specifies that it is to be served

4 OHIO FIRST DISTRICT COURT OF APPEALS

consecutively or when it is imposed for a misdemeanor violation of

[R.C.] 2907.322 [pandering sexually oriented matter involving a

minor], 2921.34 [escape], or 2923.131 [possessing a deadly weapon

while under detention] . . . .

{¶9} The next subsection, R.C. 2929.41(B)(2), pertains to sentences imposed

for multiple felony terms; therefore, it is not relevant to this appeal.

{¶10} R.C. 2929.41(B)(3) provides,

A jail term or sentence of imprisonment imposed for a

misdemeanor violation of [various traffic offenses] shall be served

consecutively to a prison term that is imposed for a felony violation of

[R.C.] 2903.06 [aggravated vehicular homicide, vehicular homicide,

and vehicular manslaughter], 2903.08 [aggravated vehicular assault

and vehicular assault], or 4511.19 [driving while intoxicated] or a felony

violation of [R.C.] 2903.04 [involuntary manslaughter] . . . involving the

operation of a vehicle by the offender and that is served in a state

correctional institution when the trial court specifies that it is to be

served consecutively.

B. Supreme Court of Ohio Precedent

{¶11} In State v. Polus, 2016-Ohio-655, ¶ 1, the Supreme Court of Ohio

considered a conflict between Ohio courts of appeals: “Whether a trial court may

impose consecutive sentences for felony and misdemeanor convictions under R.C.

2929.41(B)(1).”

{¶12} The Polus Court observed that R.C. 2929.41(A)’s first sentence states

“the general rule requiring concurrent sentencing with only clearly delineated

exceptions,” including R.C. 2929.41(B). Id. at ¶ 10. And the Polus Court determined

5 OHIO FIRST DISTRICT COURT OF APPEALS

that R.C. 2929.41(A)’s second sentence contains a specific rule: “subject only to the

exceptions stated in R.C. 2929.41(B)(3), a trial court must impose concurrent

sentences for felony and misdemeanor convictions.” Id.

{¶13} Some of R.C. 2929.41(B)’s language resulted in confusion among lower

courts. Indeed, the Polus Court noted that lower courts had erroneously interpreted

R.C. 2929.41(B)(1) in a manner contrary to the Polus Court’s ruling. Id. at ¶ 12. But the

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

Related

State v. Polus (Slip Opinion)
2016 Ohio 655 (Ohio Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 51, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-walker-ohioctapp-2026.