State v. Ibrahim
2014 Ohio 666
Ohio Ct. App.2014Background
- Appellant Mohamed Ibrahim appeals his conviction and 57-year sentence stemming from a January 2012 home invasion in which masked intruders plundered a group of Somali residents, pistol-whipped a victim causing the gun to discharge, and a shooting occurred during the disturbance.
- Appellant and a co-defendant forcibly entered the apartment, terrorized occupants, and remained for about 30 minutes.
- Appellant was charged with 47 counts and ultimately convicted of aggravated burglary (R.C. 2911.11), two counts of felonious assault (R.C. 2903.11), 11 counts of kidnapping (R.C. 2905.01), and 11 counts of aggravated robbery (R.C. 2911.01), each with firearm specifications.
- The trial court sentenced Ibrahim to a total term of 57 years imprisonment.
- Appellant argues two assignments of error: (1) the trial court failed to ensure the interpreter was qualified; (2) the sentence was an abuse of discretion that was not supported by the statutory sentencing criteria.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Interpreter qualification was proper | Ibrahim argues the interpreter was not properly qualified | Ibrahim contends the court failed to examine qualifications before use | Plain error not shown; no impact on outcome; assignment overruled |
| Sentence within statutory bounds but claimed as abuse | All individual sentences are within range; term deemed excessive | Sentence constitutes an abuse of discretion given the facts | Sentence affirmed; not an abuse of discretion |
Key Cases Cited
- State v. Kalish, 120 Ohio St.3d 23 (2008-Ohio-4912) (two-step Kalish review for felony sentences (conforms with statutory guidelines))
- State v. Long, 53 Ohio St.2d 91 (1978) (plain-error review standard for failure to raise objections in trial)
- State v. Gardner, 118 Ohio St.3d 420 (2008-Ohio-2787) (plain-error review and standard for correction of trial errors)
