State v. Bratton

Summary

The Ohio Third District Court of Appeals affirmed Lachmond Bratton’s misdemeanor conviction for violating a protection order after a no-contest plea. The court held that the prosecution’s explanation of circumstances sufficiently established the offense under Ohio Revised Code § 2919.27(A)(1) and Ohio Revised Code § 2937.07.

Holdings

1. The explanation of circumstances was not insufficient. It adequately indicated that a protection order was in place, that Bratton violated one or more of its terms, and that his repeated responses to six emails supported an inference that he acted at least recklessly.

Questions Presented

1. Whether the explanation of circumstances following Bratton's misdemeanor no contest plea sufficiently established the elements of violating a protection order under R.C. 2919.27(A)(1).
2. Whether the State's explanation sufficiently established the existence of a protection order, a violation of its terms, Bratton's identity as the violator, and the requisite reckless mental state.

Disposition

affirmed