State v. Cooper
2016 Ohio 450
Ohio Ct. App.2016Background
- On Jan. 24, 2014, while the child’s mother (Emily) slept, a five‑month‑old in her care suffered severe head injuries and died Jan. 26, 2014; cause: blunt force trauma/shaken baby syndrome.
- Original three‑count indictment charged Cooper with murder, felonious assault, and child endangering; those counts were dismissed when Cooper pled guilty by bill of information to one count of involuntary manslaughter (R.C. 2903.04(A)) under an Alford plea.
- No plea agreement on sentence; after a presentence investigation, the trial court imposed an eleven‑year sentence (the statutory maximum for a first‑degree felony).
- The presentence report included prior delinquency for gross sexual imposition, prior domestic violence/child‑endangering allegations (some reduced or uncharged), reports of prior abusive acts toward the child and mother, and Cooper’s purported lack of knowledge about how the injury occurred.
- Cooper appealed, arguing the trial court erred by imposing a maximum sentence that was inconsistent with statutory sentencing principles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by imposing the statutory maximum on involuntary manslaughter | State: sentence is lawful; trial court properly considered R.C. 2929.11/2929.12 factors and facts showing danger to the community | Cooper: maximum sentence is inconsistent with R.C. 2929.11(B) (not comparable to sentences for similar offenders) and court improperly emphasized victim’s death and lack of remorse over statutory balancing | Affirmed: trial court considered required factors, sentence within statutory range, no abuse of discretion and not contrary to law |
Key Cases Cited
- Mathis, 109 Ohio St.3d 54 (trial court must consider R.C. 2929.11/2929.12; sentence reversible if court fails to follow statute)
- Kalish, 120 Ohio St.3d 23 (appellate review of felony sentences: abuse of discretion standard)
- Alford v. North Carolina, 400 U.S. 25 (1970) (guilty plea may be entered while maintaining innocence)
- In re Kirby, 101 Ohio St.3d 312 (Ohio recognition of Alford‑type pleas)