State v. Boyd
2025 Ohio 984
Ohio Ct. App.2025Background
- Dylan Boyd was convicted of having weapons while under disability, with a firearm specification, after being found not guilty of related violent offenses by a jury.
- The events arose from Boyd allegedly shooting a former friend, E.M., in the head during a late-night reunion in Huber Heights, Ohio, after E.M. became suspicious of Boyd's behavior.
- Boyd waived a jury trial for the weapons under disability charge and was found guilty by the court in a bench trial; the jury had previously acquitted him of aggravated robbery, felonious assault, and attempted murder.
- Boyd was sentenced to 36 months for having weapons under disability, a mandatory 3 years for the firearm specification, and 713 days of post-release control from a prior conviction.
- On appeal, Boyd raised six assignments of error, including issues of jurisdiction, double jeopardy/collateral estoppel, sufficiency and manifest weight of evidence, evidentiary rulings, consideration of acquitted conduct, and the appropriateness of the sentence.
Issues
| Issue | Boyd's Argument | State's Argument | Held |
|---|---|---|---|
| Jurisdiction over firearm specification | Jury waiver covered only the underlying charge, not attached firearm specification | The specification is ancillary and tied to the underlying charge | Trial court had jurisdiction to try both; overruled |
| Collateral estoppel/double jeopardy | Acquittal of violent offenses barred subsequent trial on weapons under disability arising from the same facts | Charges are distinct; weapons charge not previously tried by jury | Double jeopardy not implicated; overruled |
| Sufficiency/manifest weight of the evidence | Conviction for weapons under disability was based on weak circumstantial evidence | Circumstantial and direct evidence (E.M.'s and Williams' testimony) | Sufficient and supported by evidence; overruled |
| Evidentiary rulings on text messages | Error to exclude/threatening messages not properly considered by the court | No actual evidence of messages to admit; lack of proffer | No error; discretion not abused; overruled |
| Consideration of acquitted conduct | Court improperly relied on facts from acquitted charges in the bench trial verdict | Court could consider evidence heard in prior jury trial | Permissible where judge presides over both; overruled |
| Sentencing appropriateness | Combined sentence and post-release term did not achieve sentencing principles; improper balancing of factors | Sentence was within statutory range; court considered all factors | Sentence lawful and supported by record; overruled |
Key Cases Cited
- State v. Lomax, 115 Ohio St.3d 350 (jury waiver requirements)
- State v. Nagel, 84 Ohio St.3d 280 (firearm specification is a penalty enhancement, not standalone)
- Ashe v. Swenson, 397 U.S. 436 (collateral estoppel as double jeopardy)
- State v. Lovejoy, 79 Ohio St.3d 440 (inconsistent verdicts on separate counts do not bar prosecution)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance of counsel standard)
- State v. Thompkins, 78 Ohio St.3d 380 (sufficiency and manifest weight analysis)