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State v. Williams

Citation: 2023 Ohio 376Docket: 111583

Court: Ohio Court of Appeals; February 8, 2023; Ohio; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, the appellant, who pleaded guilty to felonious assault after striking a victim with her vehicle, challenges her indefinite prison sentence as prescribed by the Reagan Tokes Law on constitutional grounds. The appellant contends that the law violates her rights to a jury trial and due process, as well as the separation of powers doctrine. The appellate court, referencing its decision in State v. Delvallie, upheld the constitutionality of the Reagan Tokes Law, finding the appellant's arguments unpersuasive. Consequently, the court affirmed the trial court's judgment and the imposed indefinite sentence of three to four-and-a-half years. The court also ordered that costs be taxed to the appellant and terminated any bail pending appeal, remanding the case for execution of the sentence. While concurring with the decision, Judge Eileen T. Gallagher reiterated her dissent regarding the constitutionality of the Reagan Tokes Law as previously expressed in Delvallie.

Legal Issues Addressed

Constitutionality of the Reagan Tokes Law

Application: The court applied its previous ruling, affirming the constitutionality of the Reagan Tokes Law, dismissing the appellant's claims of constitutional violations.

Reasoning: The court, referencing its prior ruling in State v. Delvallie, which upheld the constitutionality of the Reagan Tokes Law, finds Williams’s arguments unpersuasive.

Indefinite Sentencing under Reagan Tokes Law

Application: The court affirmed the imposition of an indefinite sentence as appropriate under the Reagan Tokes Law for the offense committed by the appellant.

Reasoning: She received an indefinite sentence of three to four-and-a-half years as dictated by the Reagan Tokes Law, which the court deems appropriate.

Right to Jury Trial and Due Process

Application: The appellant's argument that the Reagan Tokes Law infringes upon her right to a jury trial and due process was rejected based on precedent.

Reasoning: Daishia Williams appeals her prison sentence following a guilty plea to felonious assault, arguing that the trial court's application of the Reagan Tokes Law infringes on her constitutional rights, specifically her right to a jury trial and due process, and contravenes the separation of powers doctrine.