2018 Ohio 3015
Ohio Ct. App.2018Background
- Michael H. Goodman was convicted by jury in 2009 of aggravated robbery and related felonies for crimes committed in 2004 and was sentenced to 34.5 years; convictions were affirmed on direct appeal.
- Goodman previously sought postconviction relief and lost; those rulings were affirmed.
- In April and May 2014 Goodman filed motions requesting a payment plan for court costs; the trial court denied them and Goodman did not prevail on appeal (appellate court previously held such denials, postconviction, were not final or were barred by res judicata).
- In March 2017 Goodman moved to waive or defer court costs under the post‑2013 statute R.C. 2947.23(C); the trial court denied the motion in June 2017.
- On appeal Goodman argued the deductions from his inmate account violate the Eighth and Fourteenth Amendments; the appellate court found the appeal barred by res judicata and, alternatively, that the trial court did not abuse its discretion in denying waiver.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Goodman) | Held |
|---|---|---|---|
| Whether the trial court’s denial of a motion to waive/defer court costs is a final appealable order | Denial is final where R.C. 2947.23(C) gives courts continuing jurisdiction | Denial should be reviewable; Goodman appealed the denial | Denial is a final order under R.C. 2947.23(C) (court adopts other appellate reasoning) |
| Whether Goodman’s challenge to court‑cost deductions is barred by res judicata | Res judicata applies because issue could have been raised earlier (2014 motions or at sentencing/direct appeal) | Deductions violate Eighth/Fourteenth Amendments and deprive necessary commissary purchases | Appeal is barred by res judicata; Goodman could have raised waiver earlier |
| Whether denial of waiver/defer was an abuse of discretion on the merits | Trial court considered records showing Goodman retained funds after deductions; denial reasonable | Deductions prevent purchase of items needed in prison; constitutes cruel and unusual punishment | No abuse of discretion; record shows Goodman still had funds for commissary/filing materials |
| Whether post‑2013 R.C. 2947.23(C) applies retroactively to permit new relief | Statute permits waiver/ modification at sentencing or any time after, so trial courts have jurisdiction | Goodman contends he may invoke the statute to avoid deductions | Court treats R.C. 2947.23(C) as authorizing post‑judgment motions but holds res judicata bars this particular claim |
Key Cases Cited
- State v. Szefcyk, 77 Ohio St.3d 93 (Ohio 1996) (res judicata bars claims that were or could have been raised on direct appeal)
- State v. Threatt, 108 Ohio St.3d 277 (Ohio 2006) (abuse‑of‑discretion standard for reviewing denial of motion to waive court costs)