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State v. Daniels
2017 Ohio 1045
Ohio Ct. App.
2017
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Background

  • Defendant Courtney M. Daniels pleaded guilty in two Muskingum County cases: one for forging/uttering checks and theft totaling $7,050.61, and one for a residential burglary in which firearms and jewelry were taken.
  • Indictments: forgery (uttering) and theft (both fifth-degree felonies) in CR2016-0100; burglary (second-degree felony with firearm spec), theft of firearms (third-degree felony), misdemeanor theft, and possession of criminal tools (fifth-degree felony) in CR2016-0051.
  • Daniels admitted extensive, long-term substance abuse and a prior petty-theft criminal history; she also acknowledged selling stolen firearms and using drugs while on bond.
  • After a presentence investigation (P.S.I.), the trial court accepted guilty pleas and imposed an aggregate five-year prison term across the cases.
  • Daniels appealed, arguing the trial court failed to properly consider the purposes and principles of sentencing (R.C. 2929.11 and 2929.12) and should have used the minimum sanctions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the trial court properly considered R.C. 2929.11/2929.12 when sentencing State: trial court complied with statutory sentencing framework and imposed a lawful sentence Daniels: court failed to consider the principles and purposes of sentencing and to use minimum sanctions Court: trial court considered record, P.S.I., defendant’s drug history and criminal record; sentence within statutory range and not contrary to law; affirmed

Key Cases Cited

  • Mathis v. Ohio, 846 N.E.2d 1 (Ohio 2006) (describing R.C. 2929.11/2929.12 sentencing framework and required considerations)
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Case Details

Case Name: State v. Daniels
Court Name: Ohio Court of Appeals
Date Published: Mar 20, 2017
Citation: 2017 Ohio 1045
Docket Number: CT2016-0021, CT2016-0022
Court Abbreviation: Ohio Ct. App.