State v. Woodson
2021 Ohio 3321
Ohio Ct. App.2021Background
- Jade Woodson was indicted on multiple offenses (misdemeanors returned by grand jury) including criminal damaging and assault; she timely filed a written demand for a jury trial.
- The case proceeded in Hamilton County Municipal Court; before trial the court asked defense counsel whether Woodson had filed a jury demand and counsel (incorrectly) said she had not.
- The court conducted a bench trial, dismissed two counts, and convicted Woodson of criminal damaging and assault.
- Woodson appealed, arguing the court lacked authority to hold a bench trial because she had timely demanded a jury and never waived it in accordance with R.C. 2945.05.
- The State conceded Woodson was entitled to a jury trial. The appellate court held the trial court lacked jurisdiction to try her without a proper written, on-the-record waiver, reversed the convictions, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court could try Woodson by bench despite a filed jury demand | State conceded Woodson was entitled to a jury trial | Woodson: she timely filed a jury demand and never waived it in writing as required | Reversed: court lacked jurisdiction to try her without a strict, written waiver under R.C. 2945.05 |
| Whether a valid waiver of jury trial occurred | Implied waiver via counsel's in-court statement | No written, signed waiver in open court as required by statute | No valid waiver; strict compliance with R.C. 2945.05 required |
| Sufficiency/manifest-weight of evidence for convictions | State would argue evidence supported convictions | Woodson challenged sufficiency and weight | Moot — appellate court did not reach these issues due to jurisdictional reversal |
| Restitution order challenge | State would defend restitution as proper sentencing relief | Woodson argued restitution order was erroneous | Moot — not addressed because convictions reversed |
Key Cases Cited
- State v. Pless, 74 Ohio St.3d 333 (1996) (when defendant properly demands jury, trial court lacks jurisdiction to conduct bench trial absent strict statutory waiver)
- State v. Burnside, 186 Ohio App.3d 733 (2010) (Ohio and Sixth Amendment jury-right principles and the inviolate right under Ohio Constitution)
- State v. Sweeting, 138 N.E.3d 567 (2019) (strict compliance required for valid waiver of jury right in petty-offense context)