State v. Reeves
2014 Ohio 3497
Ohio Ct. App.2014Background
- Indicted Feb 25, 2013 on 20 counts involving rape, felonious assault, compelling prostitution, kidnapping, trafficking in persons, drug-related offenses, and witness intimidation over multiple dates in 2013.
- Reeves withdrew not-guilty pleas on July 22, 2013 and pled guilty to four counts (2, 3, 17, 19); other counts were nolled as part of a plea agreement.
- Counts 2, 3, 17, 19 carried maximum penalties; a plea negotiated dismissal of remaining counts capped exposure at a potential 127 years without the plea.
- Sentencing occurred Sept 25, 2013 after a PSI was reviewed; the court heard from the state, victim, detective, Reeves, and defense counsel.
- The court found a lengthy criminal history and the “worst form of the offense,” and imposed a consecutive 8-year term (Count 2) and 36-month terms (Counts 3, 17, 19) for a total of 17 years; Reeves appealed on Crim.R. 11 and sentencing basis.
- The appellate court affirmed, holding the Crim.R. 11 inquiry was satisfied and the sentence was within legal bounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Crim.R. 11 required a further inquiry at sentencing. | Reeves argued innocence at sentencing necessitated more inquiry. | Reeves asserted the court should probe whether plea was knowingly voluntary given his statement. | No; Crim.R. 11 satisfied; no duty to re-verify plea at sentencing. |
| Whether the court could consider dismissed charges and unproven conduct in sentencing. | Prosecutor relied on victim, detective, and dismissed charges to justify 17-year sentence. | Plea agreement and underlying facts permissible; no improper reliance on unproven conduct. | Permissible; underlying facts may be considered; sentence within statutory range. |
Key Cases Cited
- State v. Engle, 74 Ohio St.3d 525 (1996) (Crim.R. 11 requires meaningful dialogue about rights and penalties)
- State v. Minifee, 2013-Ohio-3146 (2013) (Totality of circumstances supports understanding of charge)
- State v. Schmick, 8th Dist. Cuyahoga No. 95210 (2011) (Crim.R. 11 independence from innocence claims at sentencing)