State v. Jackson

Summary

The Eighth District Court of Appeals of Ohio affirmed Jalen Jackson’s aggregate felony sentence arising from three Cuyahoga County criminal cases resolved through a global plea agreement. The court held that the sentence, which fell within the jointly recommended range and was authorized by law, was not subject to review under Ohio Revised Code 2953.08(D)(1).

Holdings

1. Because the three cases were resolved through a global plea agreement and the record contained the relevant plea and sentencing transcripts, the Court of Appeals exercised its discretion to address the merits notwithstanding the notice-of-appeal defect.
2. A sentence that is authorized by law, jointly recommended by the defendant and prosecution, and imposed by a sentencing judge is not subject to review under R.C. 2953.08(D)(1), even when the joint recommendation is expressed as a sentencing range rather than a specific term.

Questions Presented

1. Whether the Court of Appeals could address the merits when Jackson's notice of appeal omitted the case in which the most serious sentence was imposed.
2. Whether Jackson's sentence was reviewable as excessive, unsupported by the record, or contrary to law when it was authorized by law and fell within the jointly recommended sentencing range.

Disposition

affirmed