State v. Adams
2017 Ohio 8245
| Ohio Ct. App. | 2017Background
- On July 14, 2016 Jarel Adams robbed a store owner and a patron at gunpoint and tied both victims with electrical cords; both victims later identified him.
- Adams was indicted on two counts of aggravated robbery and two counts of kidnapping (all first‑degree felonies), each with a three‑year firearm specification.
- At an initial plea hearing Adams, represented by counsel, entered no‑contest pleas after the trial court indicated it would impose an aggregate seven‑year sentence contingent on the presentence investigation.
- At the scheduled sentencing the court concluded it could not legally impose seven years because statutory provisions required two separate three‑year firearm terms that must run consecutively and consecutively to the substantive terms, producing a mandatory minimum aggregate nine‑year term; the court vacated the earlier plea and conducted a new Crim.R. 11 colloquy, after which Adams again pled no contest.
- The court sentenced Adams to concurrent three‑year terms on the substantive felonies and two consecutive three‑year mandatory firearm terms (one per victim), for an aggregate nine‑year sentence, ordered restitution, and imposed post‑release control; Adams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by refusing to impose the seven‑year sentence and vacating Adams’ pleas | State: Court correctly declined to impose an unlawful sentence; no plea agreement by State forced a different result | Adams: Court should have enforced the seven‑year sentence representation and not vacate pleas | Court: No error; seven‑year sentence was contrary to law and plea was involuntary based on incorrect information, so vacatur and new plea were proper |
| Whether the court’s explanation for inability to impose seven years was incorrect or prejudicial | State: Court adequately explained it could not legally impose seven years (statutory mandatory firearm terms) | Adams: Court misstated the statutory basis (cited kidnapping rather than aggravated robbery) and that misstatement was harmful | Court: Explanation sufficiently conveyed that multiple mandatory firearm terms were required; the minor factual misstatement was harmless because nine years was statutorily required |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (procedural standard for appointed counsel to file a brief when an appeal is frivolous and for courts to conduct an independent review)