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State v. Robinson
2013 Ohio 2698
Ohio Ct. App.
2013
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Background

  • Defendant Michael Robinson pleaded guilty to one count of third-degree felony domestic violence; sentenced to 24 months’ imprisonment.
  • Charges initially included domestic violence and intimidation; plea limited to domestic violence.
  • Trial court considered the presentence investigation report, plea hearing information, victim’s letter, and oral statements at sentencing.
  • Prosecution emphasized Robinson’s extensive criminal history, including a prior domestic-violence conviction against the same victim; victim expressed fear.
  • Defense argued the court failed to consider R.C. 2929.11 and 2929.12 factors and urged alternatives to prison (counsel referenced a study suggesting prison can worsen offenders), but offered no concrete alternative sentence.
  • The court’s journal entry stated it considered all factors of law and found prison consistent with R.C. 2929.11; defendant appealed claiming the sentence was contrary to law.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the 24-month sentence is contrary to law under R.C. 2953.08(G)(2) State: Sentence falls within statutory range and record shows court considered relevant factors Robinson: Trial court failed to consider R.C. 2929.11 and 2929.12 factors before imposing prison Affirmed — sentence not contrary to law; court considered required factors and journaled its findings

Key Cases Cited

  • State v. Arnett, 88 Ohio St.3d 208 (discussing trial court’s obligation to consider statutory sentencing factors)
  • State v. Garcia, 126 Ohio App.3d 485 (defining clear-and-convincing standard)
  • State v. Miller, 127 Ohio St.3d 407 (a court speaks through its journal entries for sentencing findings)
Read the full case

Case Details

Case Name: State v. Robinson
Court Name: Ohio Court of Appeals
Date Published: Jun 27, 2013
Citation: 2013 Ohio 2698
Docket Number: 99080
Court Abbreviation: Ohio Ct. App.