State v. Young

Ohio Court of Appeals·Decided July 9, 2026·No. 2025 CA 00045·Published·Cited by 1 cases

Opinion

[Cite as State v. Young, 2026-Ohio-2603.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT

FAIRFIELD COUNTY, OHIO

STATE OF OHIO, Case No. 2025 CA 00045 Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Fairfield County Court of Common Pleas, Case No. 24 CR 583 ERIC M. YOUNG, III, Judgment: Reversed and Remanded Defendant - Appellant Date of Judgment Entry: July 9, 2026

BEFORE: Andrew J. King; Craig R. Baldwin; David M. Gormley, Judges

APPEARANCES: R. KYLE WITT, Prosecuting Attorney, MARK A. BALAZIK, Assistant Prosecuting Attorney, for Plaintiff-Appellee; COLIN E. PETERS, for Defendant-Appellant.

Baldwin, J.

{¶1} The appellant, Eric M. Young, III, appeals his sentence following his plea in the Fairfield County Court of Common Pleas. The appellee is the State of Ohio.

STATEMENT OF FACTS AND THE CASE

{¶2} On October 13, 2025, the appellant pleaded guilty to a Bill of Information charging him with one count of Involuntary Manslaughter in violation of R.C. 2903.04 with an attached three-year firearm specification pursuant to R.C. 2941.145(A). The parties entered into a jointly-recommended prison sentence of thirteen years, three years on the firearm specification and ten years on the Involuntary Manslaughter conviction, to be served consecutively. The parties further agreed that the appellant would receive two hundred ninety-

one days of jail credit and would not seek judicial release. In lieu of a transcript, the parties submitted an Agreed Statement of the Record on Appeal.

{¶3} The matter proceeded immediately to sentencing. The State argued that the ten-

year prison term on the Involuntary Manslaughter conviction was required to be designated mandatory—meaning not subject to reduction mechanisms available under Chapter 2967 of the Revised Code—by virtue of the Supreme Court of Ohio’s decision in State v. Logan, 2025- Ohio-1772. The appellant argued that Logan required only that a prison term be imposed on the underlying felony offense and did not further require that the term carry mandatory status. The trial court agreed with the State and imposed a mandatory minimum definite prison term of ten years for Involuntary Manslaughter, with an indefinite maximum term of fifteen years, consecutive to a mandatory three-year term for the firearm specification. The aggregate sentence was a mandatory minimum definite term of thirteen years and an aggregate maximum indefinite term of eighteen years.

{¶4} The appellant filed a timely notice of appeal and raised the following sole assignment of error:

{¶5} “I. THE MANDATORY ASPECT OF THE TRIAL COURT’S TEN-YEAR PRISON SENTENCE FOR INVOLUNTARY MANSLAUGHTER IS CONTRARY TO LAW.”

I.

{¶6} In his sole assignment of error, the appellant challenges the trial court’s designation of the ten-year prison term for Involuntary Manslaughter as mandatory— meaning not subject to reduction under Chapter 2967 of the Revised Code. We agree.

STANDARD OF REVIEW

{¶7} We review felony sentences under R.C. 2953.08(G)(2). An appellate court may vacate or modify a felony sentence only if it clearly and convincingly finds either that the record does not support the sentencing court’s findings under the enumerated statutes, or that the sentence is otherwise contrary to law. State v. Marcum, 2016-Ohio-1002, ¶23. Whether a trial court correctly applied a mandatory designation is a question of statutory interpretation, which this Court reviews de novo. State v. Vanzandt, 2015-Ohio-236, ¶6.

{¶8} The fundamental rule of statutory construction requires courts first to look to the plain language of the statute. Jones v. Action Coupling & Equip., Inc., 2003-Ohio-1099, ¶12. When statutory language is plain and unambiguous and conveys a clear and definite meaning, a court must rely on what the General Assembly has said and apply the statute as written. Id. Courts must read statutes as a whole, giving effect to every word and clause, and must avoid any interpretation that renders a provision meaningless or superfluous. State ex rel. Natl. Limes & Stone Co. v. Marion Cty. Bd. of Commrs., 2017-Ohio-8348, ¶¶14-16. Furthermore, statutes defining offenses or penalties must be strictly construed against the State and liberally construed in favor of the accused. R.C. 2901.04(A).

ANALYSIS

{¶9} In questions of statutory interpretation, appellate review begins with the text of the relevant statutes. Jones at ¶12. R.C. 2929.13(F) provides in pertinent part that the trial court “shall impose a prison term or terms” and “shall not reduce the term or terms . . . for any of the following offenses.” Subdivision (F)(8) then specifies:

(8) Any offense, other than a violation of section 2923.12 of the Revised Code, that is a felony, if the offender had a firearm on or about the offender’s

person or under the offender’s control while committing the felony, with respect to a portion of the sentence imposed pursuant to division (B)(1)(a) of section 2929.14 of the Revised Code for having the firearm.

{¶10} R.C. 2929.14(B)(1)(a) prescribes a mandatory prison term for the firearm specification itself. R.C. 2929.01(X)(1) defines “mandatory prison term” as, “[s]ubject to division (X)(2) of this section, the term in prison that must be imposed for the offense or circumstances set forth in divisions (F)(1) to (8) or (F)(12) to (21) of section 2929.13 and division (B) of section 2929.14 of the Revised Code.”

{¶11} Recently, the Supreme Court of Ohio’s decision in State v. Logan, 2025-Ohio-

1772, addressed a certified conflict from the Eighth District Court of Appeals framed as follows: “Does R.C. 2929.13(F)(8) require a mandatory prison term and preclude the imposition of community-control sanctions on an underlying felony when a defendant is found guilty on a corresponding firearm specification?” Id. at ¶1. The trial court in Logan had imposed a prison sentence for the firearm specification and community control for the underlying felony. Id. at ¶¶5-6. Thus, the certified question, and the Court’s answer, was directed at the threshold question of whether any prison term was required for the underlying felony at all, not at the further question of whether such a term, once imposed, is non- reducible through Chapter 2967.

{¶12} The Court’s holding reflects this limited scope: “R.C. 2929.13(F)(8) requires a trial court to impose a prison sentence on an offender convicted of a felony offense that has a corresponding firearm specification.” Logan at ¶25. That holding requires imprisonment. It says nothing about whether the required prison term is mandatory in the defined R.C. 2929.01(X)(1) sense—meaning not subject to reduction. The distinction between “must impose a prison term” and “must impose a mandatory prison term not subject to reduction” is not semantic; it is the very distinction the General Assembly drew in R.C. 2929.15(A)(1), which separately identifies sentences in which “the court is not required to impose a prison term, a mandatory prison term, or a term of life imprisonment upon the offender.” These are three distinct categories in the legislature’s drafting.

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