State v. Najmuddeen Salaam, 116 N.E.3d 195

Defendant Najmuddeen Salaam was indicted on drug offenses; bail set at $150,000 and a surety (E‑Bail Bonds, with Universal Insurance as principal/issuer) posted a $150,000 bond.
Defendant removed his GPS monitor, became a fugitive, and failed to appear for plea/trial; the state moved to forfeit bail.
The trial court forfeited the bond, entered judgment against the surety for $150,000, and allowed monthly payments; the surety paid the judgment in full.
More than a year after failure to appear, the defendant was shot and died; the prosecution later dismissed the underlying case.
The surety (Universal) moved to remit (recover) the forfeited bond monies after learning of the defendant’s death, arguing the defendant’s death made surrender impossible. The trial court denied remission; Universal appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Universal / surety)	Held
Whether the trial court erred in denying remission of a forfeited bond after the accused’s death	Remission is discretionary but statute (R.C. 2937.39) conditions remission on the accused’s appearance, surrender, or rearrest; none occurred, so denial was proper	Defendant contends death made surrender/appearance impossible (act of God/impediment) and that remission should be allowed given efforts and mitigation	Court affirmed: statute’s preconditions were not met and trial court did not abuse discretion in denying remission

Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse‑of‑discretion standard)
Crawford v. Eastland Shopping Mall Assn., 11 Ohio App.3d 158 (1983) (supports use of accelerated calendar/concise appellate disposition)