LAW.coLAW.co

State v. Alexander

2026-08-21

Summary

Holding. The judgment of the trial court is affirmed. The State did not materially breach the plea agreement, as the prosecutor clearly reaffirmed at sentencing the State's commitment to its original recommendation, and Alexander's assignment of error is overruled.

Darrol Alexander II was charged with felonious assault and domestic violence. Following plea negotiations, he agreed to plead guilty to domestic violence in exchange for dismissal of the felonious assault charge and the State's agreement to recommend community control and not seek revocation of his post-release control status. At sentencing, the prosecutor reaffirmed the State's commitment to its plea agreement recommendation. Despite this, the trial court sentenced Alexander to 18 months in prison for the domestic violence conviction plus an additional 12 months for a post-release control violation, for a total of 30 months.

Alexander appealed, claiming the State materially breached the plea agreement by failing to jointly request that the court not impose a prison term. He cited the Supreme Court's decision in Santobello v. New York for the proposition that such a breach requires either specific enforcement of the agreement or permission to withdraw his guilty plea. The appellate court found no evidence of breach, noting that the prosecutor explicitly stated at sentencing that the State would stand by its original recommendation and had found nothing in the pre-sentence investigation report that would change that position.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether the State breached a plea agreement by failing to request that post-release control not be revoked
  • Application of Santobello v. New York standards for plea agreement breaches
  • Sufficiency of the State's reaffirmation of its sentencing recommendation at the sentencing hearing

Procedural posture

Alexander appealed his conviction for domestic violence from the trial court, challenging the State's performance under the plea agreement.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as State v. Alexander, 2026-Ohio-3254.]

IN THE COURT OF APPEALS OF OHIO

SECOND APPELLATE DISTRICT

CLARK COUNTY

STATE OF OHIO :

: C.A. No. 2025-CA-95

Appellee :

: Trial Court Case No. 25-CR-0646

v. :

: (Criminal Appeal from Common Pleas

DARROL ALEXANDER, II : Court)

:

Appellant : FINAL JUDGMENT ENTRY &

: OPINION

Pursuant to the opinion of this court rendered on August 21, 2026, the judgment of

the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

send a copy of the court’s ruling to each party and note that action on the docket.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

LEWIS, P.J., and HANSEMAN, J., concur.

OPINION

CLARK C.A. No. 2025-CA-95

THOMAS W. KIDD, JR., Attorney for Appellant

JOHN M. LINTZ, Attorney for Appellee

TUCKER, J.

{¶ 1} Darrol Alexander II appeals from his conviction for domestic violence. For the

following reasons, we affirm.

I. Facts and Procedural History

{¶ 2} On August 26, 2025, Alexander was indicted on one count of felonious assault

and one count of domestic violence. At the time of the offense, Alexander was on postrelease control for a prior felony.

{¶ 3} Following plea negotiations, Alexander agreed to enter a plea of guilty to the

charge of domestic violence. In exchange, the State agreed to dismiss the charge of

felonious assault and to recommend a community control sentence. The parties also agreed

to request the trial court not to revoke Alexander’s post-release control.

{¶ 4} A plea hearing was conducted, during which the parties set forth the above

terms of the plea agreement, and Alexander entered a plea of guilty to one count of domestic

violence. The trial court accepted the plea and found Alexander guilty. A pre-sentence

investigation report was ordered, and the matter was set for sentencing.

{¶ 5} At the sentencing hearing, the prosecutor made the following statement:

At this point in time the State would be sticking with its recommendation

in the plea agreement. There’s nothing in the PSI, that the State did [not] have

a chance to review, there’s nothing there that the State was unaware of. The

reason for State’s recommendation in this case, Your Honor, is on the

2

strenuous wishes of the victim. She was informed of today’s hearing, stated

that she did not want to appear in court.

We also told her she could write the Court a letter but she never got one

to us. So I’m doing my best to relay her wishes at this point and that is because

obviously Mr. Alexander did go to prison just a few years ago. After he was

released from prison, the victim has stated that he has not been the same

person that he was before he went and she feels that counseling and

vocational training that West Central would provide would get Mr. Alexander

back to who he was before he went to prison.

And that’s why the State made the recommendation that it did to try and

maintain her cooperation with the case. And, also, the State feels that

counseling and vocational training would be helpful to Mr. Alexander as well.

{¶ 6} The trial court found Alexander in violation of post-release control. It sentenced

him to a prison term of 18 months for the domestic violence conviction to be served

consecutively to a 12-month term for the post-release control violation, yielding an aggregate

sentence of 30 months. Alexander appeals.

II. Breach of Plea Agreement

{¶ 7} The sole assignment of error asserted by Alexander states:

The State materially breached the plea agreement by failing to fulfill its

obligation to jointly request that the court not impose a prison term under

R.C. 2929.141. This constitutes reversible error under the principles of

Santobello v. New York and Ohio contract-based plea-agreement

jurisprudence.

3

{¶ 8} Alexander claims the State breached the plea agreement by failing to request

that the trial court not find him in violation of the terms of post-release control. Citing

Santobello v. New York, 404 U.S. 257 (1971), he claims that this matter should be remanded

to the trial court with instructions either to specifically enforce the agreement or to allow him

to withdraw the plea.

{¶ 9} In Santobello, the defendant and the State entered into a plea agreement in

which the prosecutor would make no recommendation as to the sentence. Id. at 258.

Santobello entered a guilty plea, which was accepted by the trial court. Id. A sentencing

hearing followed later, and a different prosecutor appeared for the State and asked the court

to impose the maximum sentence. Id. at 259. Defense counsel objected, but the trial court

nonetheless sentenced the defendant to the maximum term. Id. at 260. On appeal, the

United States Supreme Court held:

[T]he interests of justice and appropriate recognition of the duties of the

prosecution in relation to promises made in the negotiation of pleas of guilty

will be best served by remanding the case to the state courts for further

consideration. . . . [W]e leave to the discretion of the state court . . . whether

the circumstances . . . require only that there be specific performance of the

agreement on the plea . . . or . . . the circumstances require granting . . .

petitioner . . . the opportunity to withdraw his plea of guilty.

(Footnote omitted.) Id. at 262-263.

{¶ 10} In Santobello, the State obviously breached the plea agreement when the new

prosecutor not only failed to refrain from making a sentencing recommendation but also

requested the maximum sentence. Here, the record does not support a conclusion that the

State breached the plea agreement.

4

{¶ 11} Alexander argues the breach occurred during the sentencing hearing when

the State failed to specifically reiterate that “the parties would ask the Court not to violate

[Alexander’s] post-release control.” However, at the sentencing hearing, the prosecutor

clearly stated that the State would adhere to the terms of the plea agreement and that

nothing in the PSI would cause the State to question that agreement, which had been

specifically set forth on the record during the plea hearing.

{¶ 12} We find there is no basis to Alexander’s claim that the State breached the plea

agreement and thus conclude his argument lacks merit. Accordingly, the sole assignment of

error is overruled.

III. Conclusion

{¶ 13} Alexander’s assignment of error being overruled, the judgment of the trial court

is affirmed.

LEWIS, P.J., and HANSEMAN, J., concur.

5