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State v. Boyd

2026-08-24

Summary

Holding. The trial court did not err in imposing Boyd's Failure to Comply sentence consecutively to his other prison terms because Ohio law requires such sentences to be served consecutively by operation of law, eliminating the need for discretionary consecutive-sentence findings. The judgment is affirmed.

TraJean Boyd was charged with several offenses stemming from a 2020 high-speed vehicle pursuit and subsequent discovery of counterfeiting equipment. He was eventually convicted in other jurisdictions for counterfeiting-related crimes and received both state and federal sentences. In 2025, Boyd pleaded guilty to Failure to Comply, Forgery, and Identity Fraud in Madison County. The trial court sentenced him to 30 months for the Failure to Comply conviction and ordered that term to run consecutively to his federal sentence, while the other terms ran concurrently. Boyd appealed, arguing that the trial court failed to make required findings before imposing a consecutive sentence. The appellate court rejected this argument because state law mandates that sentences for Failure to Comply under the applicable statute must run consecutively to any other prison terms, making discretionary findings unnecessary.

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

Key issues

  • Whether consecutive-sentence findings were required before imposing a term consecutive to a federal sentence
  • Mandatory consecutive sentencing requirement for Failure to Comply violations under Ohio Revised Code 2929.14(C)(3)
  • Standard of appellate review for felony sentences under R.C. 2953.08(G)(2)

Procedural posture

Boyd appealed his sentence imposed by the Madison County Court of Common Pleas to the Twelfth Appellate District of Ohio.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as State v. Boyd, 2026-Ohio-3287.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

MADISON COUNTY

STATE OF OHIO, :

CASE NO. CA2025-11-031

Appellee, :

OPINION AND

vs. : JUDGMENT ENTRY

8/24/2026

TRAJEAN E. BOYD, :

Appellant. :

:

CRIMINAL APPEAL FROM MADISON COUNTY COURT OF COMMON PLEAS

Case No. CRI 20220258

Nicholas A. Adkins, Madison County Prosecuting Attorney, and Michael S. Klamo, Chief Assistant Prosecutor, for appellee.

Shannon M. Treynor, for appellant.

OPINION

PIPER, P.J.

{¶ 1} Appellant, TraJean E. Boyd, appeals his sentence in the Madison County

Court of Common Pleas. For the reasons set forth below, we affirm.

Madison CA2025-11-031

I. Factual and Procedural Background

{¶ 2} On October 31, 2020, Boyd was driving 100 mph on Interstate 70 when a

state trooper initiated a pursuit. Boyd refused to stop and accelerated to speeds reaching

120 mph. During the pursuit, Boyd used both the left shoulder and right berm to pass

other vehicles. Boyd eventually exited onto State Route 42, where he continued fleeing

at speeds between 90 and 100 mph. He weaved through traffic, crossed a double-yellow

line, and nearly collided with an oncoming vehicle. The trooper terminated the pursuit

after Boyd entered the London city limits because of the danger to other motorists and

bystanders. Boyd later abandoned his vehicle behind a Kroger grocery store, fled on foot,

and was eventually arrested. London police recovered Boyd’s vehicle and discovered

counterfeiting equipment inside.

{¶ 3} On November 6, 2020, Boyd was indicted in Madison County on two

charges: Failure to Comply, in violation of R.C. 2921.331(B), a third-degree felony; and

Receiving Stolen Property, in violation of R.C. 2913.51(A), a fifth-degree felony. On March

2, 2021, Boyd failed to appear for a pretrial hearing, and the court issued a capias. While

the Madison County case stood pending, Boyd was arrested in several other counties

and was ultimately convicted of multiple state and federal counterfeiting offenses.

Beginning in June 2022, Boyd remained continuously incarcerated for his other state

offenses. He also received a four-year federal sentence, which he was ordered to serve

after completing his state prison terms.

{¶ 4} On December 16, 2022, a second indictment was filed in Madison County.

That indictment charged Boyd with Forgery, in violation of R.C. 2913.31(A)(3), a fifthdegree felony; Possession of Criminal Tools, in violation of R.C. 2923.24(A), a fifth-2-Madison CA2025-11-031

degree felony; Counterfeiting, in violation of R.C. 2913.30(B)(4), a third-degree felony;

and two counts of Identification Fraud, in violation of R.C. 2913.49(B)(1), both fifth-degree

felonies.

{¶ 5} After Boyd completed his prison terms for the other state offenses, but

before he began serving his federal sentence, he was transferred back to Madison

County. On September 16, 2025, Boyd pleaded guilty to Failure to Comply, Forgery, and

one count of Identity Fraud. The remaining counts were dismissed.

{¶ 6} The trial court held a sentencing hearing on October 24, 2025. The court

imposed a 30-month prison term for Boyd’s Failure to Comply offense and ordered that

term to run consecutively to his federal sentence. The court also imposed six months for

Forgery and six months for Identity Fraud. Those terms were ordered to run concurrently

with each other and with Boyd’s federal sentence, but consecutively to the Failure to

Comply sentence, resulting in an aggregate 36-month prison sentence as to this case.

{¶ 7} Boyd now appeals, raising one assignment of error for our review.

II. Legal Analysis

{¶ 8} Assignment of Error No. 1:

THE COURT ERRED BY IMPOSING SENTENCE

CONSECUTIVE TO THE DEFENDANT'S FEDERAL

PENITENTIARY SENTENCE IMPOSED BUT NOT YET

SERVED.

{¶ 9} In his single assignment of error, Boyd argues the trial court erred by

"imposing the entirety of the sentence consecutive to that of the Federal sentence

imposed, but not yet served" without first making findings pursuant to R.C. 2929.14(C)(4).

This is inaccurate; the trial court only ordered the 30-month term for his Failure to Comply

Offense to run consecutive to his federal sentence, while it explicitly stated that his six-3-Madison CA2025-11-031

month terms for his two other offenses would run concurrently to each other and to his

federal sentence. The parties agree that the trial court made no consecutive-sentence

findings. However, as the State correctly notes, those findings were unnecessary

because Boyd’s sentence for Failure to Comply was required by law to be served

consecutively.

{¶ 10} We review the imposed sentence under the standard of review set forth in

R.C. 2953.08(G)(2), which governs all felony sentences. State v. Marcum, 2016-Ohio1002, ¶ 1; State v. Abrams, 2017-Ohio-8536, ¶ 11 (12th Dist.). Pursuant to that statute,

an appellate court does not review the sentencing court's decision for an abuse of

discretion. Marcum at ¶ 10. Rather, R.C. 2953.08(G)(2) compels an appellate court to

modify or vacate a sentence only if the appellate court finds by clear and convincing

evidence that "the record does not support the trial court's findings under relevant statutes

or that the sentence is otherwise contrary to law." Id. at ¶ 1.

{¶ 11} R.C. 2929.14(C)(3) provides that if a prison term is imposed for a violation

of "2921.331 of the Revised Code, the offender shall serve that prison term consecutively

to any other prison term or mandatory prison term previously or subsequently imposed

upon the offender." (Emphasis added.) That is precisely the situation here. The trial court

had no discretion to impose other than a consecutive sentence for Boyd's violation of R.C.

2921.331(B), and his other prison terms were ordered to run concurrent to his federal

sentence, therefore consecutive sentence findings were not necessary. "The

consecutive-sentencing provisions of R.C. 2929.14(C)(4) are inapposite when the trial

court is required to impose consecutive sentences by operation of law." State v. Harper,

2017-Ohio-8963, ¶ 16 (1st Dist.).

-4-Madison CA2025-11-031

III. Conclusion

{¶ 12} We find the trial court did not err in imposing Boyd's Failure to Comply

sentence consecutive to his other prison terms. The sole assignment of error is overruled.

{¶ 13} Judgment affirmed.

M. POWELL and SIEBERT, JJ., concur.

JUDGMENT ENTRY

The assignment of error properly before this court having been ruled upon, it is the order of this court that the judgment or final order appealed from be, and the same hereby is, affirmed.

It is further ordered that a mandate be sent to the Madison County Court of Common Pleas for execution upon this judgment and that a certified copy of this Opinion and Judgment Entry shall constitute the mandate pursuant to App.R. 27.

Costs to be taxed in compliance with App.R. 24.

/s/ Robin N. Piper, Presiding Judge

/s/ Mike Powell, Judge

/s/ Melena S. Siebert, Judge

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