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State v. Bell (Slip Opinion)
2016 Ohio 7561
| Ohio | 2016
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Background

  • 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)
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Case Details

Case Name: State v. Bell (Slip Opinion)
Court Name: Ohio Supreme Court
Date Published: Nov 2, 2016
Citation: 2016 Ohio 7561
Docket Number: 2015-0947 2015-0994 2015-1273 2015-1357 2015-1592 2015-1767 2015-1810 2015-1950 2015-1986 2015-1987 2015-1988 2015-2043 and 2016-0490
Court Abbreviation: Ohio