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Ohio Case Law

State v. Pratt, 2025-Ohio-2611

Case Information

Court: Court of Appeals of Ohio, Second Appellate District, Champaign County
Date: 2025-07-25
Citation: 2025-Ohio-2611
Read the Opinion

Summary

Summary: The Court of Appeals of Ohio reversed a misdemeanor conviction against the Defendant for permitting cattle to run at large, finding that the trial court failed to establish the requisite mental state of recklessness necessary for conviction under R.C. 951.02.

Key Holdings

  • A no contest plea in a misdemeanor case requires the State to establish all elements of the offense including mens rea.
  • Recklessness is required for a conviction under R.C. 951.02 according to R.C. 951.99.
  • Evidence that animals escaped due to a spontaneous event without prior incidents or ignored warnings does not meet the recklessness standard.
  • Information provided post-conviction cannot retroactively satisfy the explanation-of-circumstances requirement under R.C. 2937.07.

More Information

The Defendant was charged under R.C. 951.02 for permitting his cattle to run at large after they entered a public road and were struck by vehicles. He entered a no contest plea without counsel, and the trial court convicted and sentenced him to a suspended jail term and a fine. The Defendant appealed, asserting that the State failed to prove he acted recklessly.

On appeal, the Court applied de novo review and emphasized that a conviction based on a no contest plea must be supported by an explanation of circumstances that establishes each element of the offense, including mens rea. Under R.C. 951.99, a violation of R.C. 951.02 requires proof of recklessness, defined by R.C. 2901.22(C).

The appellate court found the facts insufficient to establish recklessness. The evidence only showed the cattle had broken through a gate or barn without prior incidents or warnings indicating negligence. Unlike in a previous case where recklessness was established by repeated escapes and ignored repair requests, no such facts were present here.

The court also noted that the prosecutor’s mention of a prior conviction occurred after the guilty finding and could not be used to establish the mental state element. As a result, the trial court’s judgment was vacated due to insufficient evidence of the required culpable mental state.