State v. Bell (Slip Opinion)
2016 Ohio 7561
| Ohio | 2016Background
- The Ohio Supreme Court considered multiple consolidated appeals from the Eighth District Court of Appeals challenging sentencing decisions.
- Each appellate judgment was reviewed in light of this court’s decision in State v. Thomas (2016-Ohio-5567), which addressed application of sentencing law.
- The Supreme Court affirmed the courts of appeals in a series of cases (listed by docket), holding they were controlled by the Thomas decision.
- Five justices concurred in affirming; two justices (O’Donnell and Kennedy) dissented, arguing the trial-court sentences should be reinstated or defendants resentenced under the law in effect at the time of the offenses.
- The opinions collectively resolved whether the lower-court sentences should stand under the controlling precedent established in Thomas.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellate judgments should be affirmed under State v. Thomas | The State: Thomas controls and mandates affirmance of the appeals | Defendants: Thomas should not control; trial sentences should be reinstated or resentenced under older law | Affirmed — courts of appeals judgments upheld on authority of State v. Thomas |
| Retroactive application of sentencing rules | The State: Thomas applies to these cases as controlling precedent | Defendants: Applying Thomas retroactively violates their rights; sentencing should follow law at offense time | Held for the State — Thomas governs these appeals |
| Proper remedy for alleged sentencing error | The State: No relief; affirm appellate judgments | Defendants: Reverse and remand to trial courts for sentences under prior law | Affirmed — no remand; appellate judgments stand per Thomas |
| Effect of dissenting justices' view | N/A (majority) | Dissent: reinstate trial-court sentences or remand to apply law in effect at offense | Dissent noted but majority opinion controls and affirms the courts of appeals |
Key Cases Cited
- State v. Thomas, Ohio St.3d (2016) (controlling decision regarding the sentencing issue that governed these appeals)
