State v. Coon, 2025 Ohio 1849

Timothy Coon was indicted on multiple charges following an incident where, after initiating a 911 call, he threatened two people and confronted police with a machete at his residence.
Charges included retaliation, inducing panic, aggravated menacing, obstructing official business, and resisting arrest; the most severe charge he pled to was obstructing official business (fifth-degree felony).
Coon underwent a mental health evaluation and was released on bond, but violated bond conditions several times (missed curfews, drug testing).
In April 2024, Coon entered guilty pleas to aggravated menacing and obstructing official business in exchange for dismissal of remaining charges.
The trial court sentenced Coon to 11 months in prison for obstructing official business and 35 days in jail for aggravated menacing, rejecting community control due to Coon's insistence against probation and his bond violations.
Coon appealed his convictions, challenging the validity of his guilty plea and the trial court's sentencing decision.

Issue	Coon's Argument	State's Argument	Held
Was Coon's guilty plea entered knowingly, intelligently, and voluntarily?	Coon claimed his mental and physical condition were not sufficiently inquired into, rendering his plea invalid.	The State asserted the record showed Coon was competent, understood the proceedings, and the plea process was proper under Crim.R. 11.	Plea was valid; record showed knowing and voluntary plea.
Did the trial court err by imposing prison instead of community control?	Coon argued the trial court abused discretion by sentencing him to prison instead of alternative sanctions, given his amenability to community control.	The State emphasized Coon's bond violations gave the trial court discretion for imprisonment, and argued sentencing followed Ohio law.	No error; trial court’s decision supported and affirmed.

State v. Hart, 2024-Ohio-5622 (requirements for knowing, intelligent, voluntary guilty plea)
State v. Mull, 2024-Ohio-370 (plea requirements)
State v. Dangler, 2020-Ohio-2765 (Crim.R. 11 and appellate review)
State v. Stone, 43 Ohio St.2d 163 (purpose of Crim.R. 11 plea colloquy)
State v. Jones, 2020-Ohio-6729 (limits on appellate review of trial court’s sentencing discretion under R.C. 2929.11 and 2929.12)
State v. Davis, 2024-Ohio-5135 (application of Jones to appellate review)
State v. Eames, 2024-Ohio-183 (appellate review of sentencing factors)
State v. Bowles, 2021-Ohio-4401 (appellate deference to trial court in sentencing)