State v. Long, 2016 Ohio 5345

Defendant Keith Long pleaded guilty to violating a protection order (R.C. 2919.27(A)(2)) and faced sentencing in Hamilton County Common Pleas Court.
At sentencing the court asked Long if he had anything to say; Long apologized and stated he would have no further contact with the victim.
The court commented on Long’s prior domestic incidents and referenced the presentence investigation (PSI) and victim-impact statement.
Long attempted to speak again after the court referred to the PSI, but the judge cut him off, saying he would not continue the exchange.
Long appealed, arguing the trial court denied his Crim.R. 32(A)(1) right of allocution by refusing to let him address information discussed after he had already spoken.
The First District Court of Appeals affirmed, finding Long had been asked if he wanted to speak, had received the PSI in advance, and was not deprived of allocution under the circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court denied Long his Crim.R. 32(A)(1) right of allocution	State: Court properly afforded allocution when it asked Long if he had anything to say and listened	Long: Court cut him off after discussing PSI information, preventing him from addressing new/changed information	Court held no denial: Long was asked directly, had the PSI beforehand, and was not prevented from addressing new information

State v. Green, 90 Ohio St.3d 352 (2000) (Crim.R. 32 allocution is a defendant’s last opportunity to plead his case or express remorse; courts must "painstakingly adhere")
State v. Campbell, 90 Ohio St.3d 320 (2000) (if court sentences without affording allocution, resentencing is required unless error is invited or harmless)
State v. Yates, 958 N.E.2d 640 (2011) (appellate case holding defendant must be allowed to address new information raised at sentencing)