State v. Roach, 2016 Ohio 4656

Appellant Scott Michael Roach threw a sippy cup of milk at his six‑year‑old autistic son, causing a bruise; charged with fourth‑degree felony child endangering (prior child rape conviction elevated the offense).
Roach pled guilty and the court ordered a presentence investigation and victim impact statement.
At sentencing, defense counsel described remedial steps (completed a 12‑week domestic abuse program), urged non‑serious injury, and requested community control with EOCC placement.
The trial court asked Roach personally if he wished to speak; Roach said, “I wished it would never have happened, but…,” the court responded, and Roach then said, “I understand that.”
The court sentenced Roach to the maximum 18 months imprisonment; Roach appealed, arguing the court cut him off and thus denied his Crim.R. 32(A)(1) right of allocution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Roach was denied his Crim.R. 32(A)(1) right of allocution	State: Court personally invited defendant to speak and any brief interruption did not deprive allocution; any error was harmless.	Roach: Court interrupted him mid‑sentence after he began allocuting and failed to give further opportunity to speak, violating Crim.R. 32(A)(1).	Court affirmed: personal invitation was made, record shows Roach trailed off (not clearly interrupted), he had further opportunity (and spoke), counsel also allocuted and submitted mitigation, so no prejudicial violation.

Green v. United States, 365 U.S. 301 (Supreme Court definition of the personal‑invitation allocution requirement)
State v. Green, 90 Ohio St.3d 352 (Ohio 2000) (trial court must personally ask defendant to speak; invitation must be unambiguous)
State v. Campbell, 90 Ohio St.3d 320 (Ohio 2000) (allocution right can be waived by silence; errors reviewed for invited‑error and harmless‑error doctrines)
State v. Reynolds, 80 Ohio St.3d 670 (Ohio 1998) (example where allocution omission was found harmless given other opportunities to express remorse)