State v. Williams

Summary

The Ohio Twelfth District Court of Appeals affirmed Germaine Montel Williams's sentence following his guilty plea to aggravated assault. The court held that Williams's challenge to a community-control condition restricting his presence on Kunz Avenue was procedurally barred under the invited-error doctrine and, alternatively, that the condition was neither overbroad nor unreasonable.

Holdings

1. The invited-error doctrine barred Williams from obtaining relief because he and his counsel actively participated in crafting the restriction and agreed to the condition that he later challenged.
2. The restriction on Williams's presence in the Kunz Avenue neighborhood was not overbroad or unreasonable and did not constitute plain error.
3. Because Williams did not object to the community-control condition in the trial court, any review was limited to plain error, and no plain error occurred.

Questions Presented

1. Whether the trial court committed plain error by imposing a community-control condition restricting Williams's presence on Kunz Avenue.
2. Whether the condition was overbroad and unreasonable because it allegedly required Williams to leave his residence and was not reasonably related to rehabilitation, the offense, or preventing future criminality.
3. Whether the invited-error doctrine barred Williams from challenging a community-control condition that he and his counsel helped formulate.

Disposition

affirmed