State v. Guzman, 2017 Ohio 682

Roberto Guzman was indicted for possession of cocaine (first-degree felony) and released on a $100,000 surety bond posted through Erie Shore Bail Bonds (Scott Hunter).
After Guzman pled no contest and was sentenced to an eight-year mandatory term, the trial court set an appeal bond at $150,000; Guzman posted an additional $50,000 through the same surety.
Guzman failed to appear for a show-cause hearing and the trial court ordered the $150,000 bond forfeited and entered judgment against the surety.
The surety later apprehended Guzman and moved for remission of the forfeited bond under R.C. 2937.39, claiming it had located and captured Guzman and incurred expenses doing so.
The trial court granted partial remission, returning $5,000 to the surety and retaining $145,000; the surety appealed, arguing the full $150,000 should have been remitted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by remitting only $5,000 of a $150,000 forfeited bond	State: trial court properly weighed factors and should retain most of forfeiture to vindicate prejudice and procedural costs	Surety (Hunter): quickly located and apprehended Guzman, expended effort and $5,000; state not prejudiced — remit full $150,000	Court affirmed: no abuse of discretion; $5,000 remission affirmed

State v. Patton, 60 Ohio App.3d 99 (6th Dist. 1989) (discusses standard for bond forfeiture and remission)
State v. Am. Bail Bond Agency, 129 Ohio App.3d 708 (10th Dist. 1998) (enumerates factors appropriate for remission decisions)
State v. Duran, 143 Ohio App.3d 601 (6th Dist. 2001) (remission balancing test and surety conduct considerations)
State v. Jackson, 153 Ohio App.3d 520 (3d Dist. 2003) (remission requires balancing reappearance and surety efforts against state’s prejudice)
State v. Adams, 62 Ohio St.2d 151 (Ohio 1980) (defines abuse of discretion standard)