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Ohio Case Law

State v. Singleton, 2025-Ohio-4849

Case Information

Court: Court of Appeals of Ohio Eighth Appellate District County of Cuyahoga
Date: 2025-10-23
Citation: 2025-Ohio-4849
Read the Opinion

Summary

Summary: Defendant appealed the imposition of a no-contact order accompanying a prison sentence following guilty pleas to unlawful sexual conduct with a minor and strangulation. The appellate court vacated the no-contact order, finding it constituted an unauthorized hybrid sentence under Ohio law.

Key Holdings

  • A no-contact order is a community-control sanction and cannot be imposed alongside a prison sentence for the same felony offense
  • A defendant’s agreement to an unauthorized sentence does not grant the court statutory authority to impose it
  • The imposition of a hybrid sentence involving prison and community-control sanctions constitutes plain error
  • The court must vacate unauthorized portions of a sentence even if agreed upon in a plea deal

More Information

The Defendant-Appellant was convicted after pleading guilty to unlawful sexual conduct with a minor and strangulation. The charges stemmed from an incident in which a 14-year-old girl, attempting to run away, stayed with the Defendant for about a week, during which time he engaged in sexual conduct with her. As part of a plea deal, the State asserted the Defendant agreed to a no-contact order. The trial court imposed a 54-month prison sentence and included the no-contact order as part of the final sentence.

On appeal, the Defendant challenged only the no-contact order, not the underlying convictions or sentence length. The appellate court analyzed whether a trial court may impose both a prison term and a community-control sanction (such as a no-contact order) for the same felony offense. Citing Ohio precedent, including State v. Anderson and State v. Nelson, the court emphasized that such hybrid sentences are unauthorized by statute and cannot be imposed even if the defendant agrees to them in a plea.

The State contended that any error was invited by the Defendant through his agreement to the order. However, the court clarified that under binding precedent, courts cannot impose unauthorized sentences regardless of any agreement between the parties. The appellate court applied a plain-error analysis, concluding that the error was both obvious and prejudicial.

The opinion also discussed inconsistencies within the appellate district’s prior rulings, particularly contrasting State v. Smith and State v. Reeder, highlighting ongoing conflict regarding whether invited-error or plain-error doctrines apply in such cases. Ultimately, the court followed the Reeder plurality, applying plain-error review and vacating the no-contact order due to its unauthorized nature. The case was remanded solely to remove the no-contact provision from the sentencing entry.