State v. Chambers
2025 Ohio 1320
Ohio Ct. App.2025Background
- Nathaniel Chambers was convicted of first-degree misdemeanor domestic violence following an altercation where he pushed the mother of his children, Alyssa Krebs, causing her to fall and lose consciousness while their children witnessed the event.
- Chambers was sentenced to 180 days in jail (90 suspended) and five years of community control, including a five-year no-contact order with both Krebs and his children.
- Krebs described Chambers as a good father, and there was no evidence or finding of abuse, neglect, or threats posed to the children by Chambers.
- Chambers appealed specifically the no-contact condition regarding his children, arguing its overbreadth and lack of connection to rehabilitation.
- The appeal centered on whether the trial court abused its discretion by imposing a categorical, lengthy no-contact order between Chambers and his children.
Issues
| Issue | Chambers' Argument | State's Argument | Held |
|---|---|---|---|
| Validity of 5-year no-contact order with children as community control condition | No evidence of child abuse or neglect, children not victims, restriction not reasonably related to rehabilitation | Chambers involved children in incident by taking them to volatile situation; restriction justified to protect children | Reversed: Condition not reasonably related to rehabilitation; overbroad and punitive |
Key Cases Cited
- State v. Jones, 49 Ohio St.3d 51 (Ohio 1990) (establishes three-part test for validity of community-control conditions)
- State v. Talty, 103 Ohio St.3d 177 (Ohio 2004) (conditions must not be overly broad and must be reasonably related to rehabilitation)
- Troxel v. Granville, 530 U.S. 57 (U.S. 2000) (fundamental liberty interest in care and custody of children)
- State v. Brillhart, 129 Ohio App.3d 180 (Ohio Ct. App. 9th Dist. 1998) (invalidating no-contact order with children absent connection to offense)