State v. Ledbetter, 2017 Ohio 89

Police observed suspected drug trafficking at a house across from a Cleveland police station, executed a controlled buy, and then searched the home. Officers found large quantities of oxycodone, marijuana, guns, cash, and a 12‑year‑old child present.
John C. Ledbetter and his fiancée were arrested; Ledbetter accepted a plea agreement pleading guilty to multiple counts including second‑degree drug trafficking with juvenile and firearm specifications, lesser trafficking and possession counts, and child endangerment.
The plea agreement included forfeiture of phones, money, firearms, and ammunition. The court conducted a Crim.R. 11 colloquy and ordered PSI and supervised‑release eligibility reports.
At sentencing the court merged allied trafficking counts, the state elected sentencing on the second‑degree trafficking count, and the court imposed 4 years (3 years for trafficking consecutive to 1‑year firearm specification), concurrent terms on lesser counts, a mandatory $7,500 fine, and court costs.
Ledbetter appealed, arguing (1) the sentence exceeds the minimum and is contrary to law and (2) imposing fines and costs violated his rights because he was indigent.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Ledbetter)	Held
Whether the 4‑year aggregate sentence (3 yrs trafficking + 1 yr firearm spec) is contrary to law	The trial court considered R.C. 2929.11/2929.12 factors and fashioned a proportional sentence for organized, flagrant trafficking in presence of a child and a firearm	Sentence is greater than the minimum and therefore contrary to law	Affirmed — appellate review requires clear and convincing showing; court properly considered required factors and record supports sentence
Whether imposing $7,500 mandatory fine and court costs violated Ledbetter’s rights as an indigent defendant	Mandatory fine is required by statute unless defendant files an affidavit of indigency prior to sentencing and court finds inability to pay; court has discretion to waive costs but Ledbetter did not file affidavit	Ledbetter contends he is indigent (pointing to appointment of counsel) and court should have waived fines and costs	Affirmed — Ledbetter failed to file affidavit of indigency; appointment‑of‑counsel indigency is not dispositive for fines; court did not abuse discretion

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard for appellate review of felony sentences requires clear and convincing evidence to modify or vacate)
Cross v. Ledford, 161 Ohio St. 469 (Ohio 1954) (definition of clear and convincing evidence)
State v. Gipson, 80 Ohio St.3d 626 (Ohio 1998) (mandatory fine statutes require affidavit of indigency filed before sentencing to avoid fine)
State v. Joseph, 125 Ohio St.3d 76 (Ohio 2010) (defendant must file affidavit addressing present and future ability to pay for court to waive fines/costs)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (standard for abuse of discretion review)