State v. Satchel, 2018 Ohio 623

Appellant Omar Satchel was indicted for grand theft and for possessing a firearm while under a disability; the grand theft count was dismissed and the possession charge was tried to a jury.
Evidence: Margaret Sims purchased a Cobra .380 handgun; the gun was later missing from her home.
Detective O’Connell investigated a homicide and believed the missing .380 might be the murder weapon; he interviewed Satchel after arrest.
Satchel admitted to taking the Cobra .380 from Sims on April 4 and selling it during a trip to Detroit; his confession was the only direct evidence placing the gun with him on April 4.
The jury convicted Satchel of possessing a firearm while under a disability; the trial court immediately sentenced him to the maximum three-year term without ordering a presentence investigation.
Satchel appealed, arguing the sentence reflected an unconstitutional "trial tax"—i.e., vindictiveness for exercising his right to a jury trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sentence was a vindictive "trial tax" for exercising right to jury trial	Satchel: court punished him for making the jury hear the case (court comment about "40 people off the street")	State: no evidence of actual vindictiveness; sentence supported by record	Court: No. Isolated comment inappropriate but insufficient to show actual vindictiveness; sentence not contrary to law

State v. Rahab, 80 N.E.3d 431 (Ohio 2017) (sentence vindictively imposed for exercising jury-trial right is contrary to law; appellate review looks for actual vindictiveness in the whole record)
State v. Adams, 525 N.E.2d 1361 (Ohio 1988) (decision to order a presentence report is within trial court's discretion)