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State v. Ramsey

2026-08-26

Summary

Holding. The appellate court affirmed the trial court's denial of Ramsey's motion, holding that his challenges to the SVP specifications were barred by res judicata because they could have been raised on his original direct appeal in 2015 and were not.

Rashaun Ramsey was convicted in 2014 of rape, kidnapping, drug possession, and failure to notify of a change of address. The trial court found him guilty of sexually violent predator (SVP) specifications on the rape and kidnapping counts after a bench trial on those specifications. Ramsey received a sentence of twenty-five years to life. His direct appeal in 2015 was unsuccessful. In 2023, he filed a motion challenging whether specifications on one of the kidnapping counts had been properly resolved. This appeal was also rejected based on res judicata. In April 2026, Ramsey filed another motion attacking the trial court's application of the SVP statute, arguing the court erred in its legal interpretation of how to determine future dangerousness. The trial court denied this motion in May 2026.

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

Key issues

  • Whether res judicata bars post-conviction challenges to sentencing enhancement specifications
  • Whether trial court properly applied the statutory framework for finding sexually violent predator specifications
  • Whether future dangerousness determination must be independent from historical conviction evidence

Procedural posture

This appeal concerns the trial court's May 8, 2026 denial of a motion challenging sexually violent predator specifications imposed during a 2014 bench trial, following the defendant's conviction by jury and a prior unsuccessful direct appeal in 2015.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as State v. Ramsey, 2026-Ohio-3335.]

IN THE OHIO COURT OF APPEALS

FIFTH APPELLATE DISTRICT

RICHLAND COUNTY, OHIO

STATE OF OHIO Case No. 2026 CA 0049

Plaintiff - Appellee Opinion and Judgment Entry

-vs- Appeal from the Richland County Court of

Common Pleas, Case No. 14-CR-0343R

RASHAUN M. RAMSEY

Judgment: Affirmed

Defendant - Appellant

Date of Judgment Entry: August 26, 2026

BEFORE: William B. Hoffman; Craig R. Baldwin; Robert G. Montgomery, Judges

APPEARANCES: Jodie M. Schumacher, Richland County Prosecuting Attorney, Michelle Fink, Assistant Prosecuting Attorney, for Plaintiff-Appellee; Rashaun Ramsey, Pro se, for Defendant-Appellant.

Hoffman, P.J.

{¶1} Defendant-Appellant Rashaun M. Ramsey appeals the May 8, 2026, Judgment

Entry entered in the Richland County Common Pleas Court denying his “motion to vacate

sexually violent predator specification and to correct sentence not authorized by law.”

Plaintiff-Appellee is the State of Ohio.

STATEMENT OF THE CASE AND FACTS

{¶2} On June 5, 2014, the Richland County Grand Jury indicted Appellant on one

count of Rape, in violation of R.C. §2907.02(A)(2), a first-degree felony, two counts of

Kidnapping, in violation of R.C. §2905.01(A)(3) and (4), first-degree felonies, one count of

Possession of Heroin, in violation of R.C. §2925.11(A) & (C)(6)(a), a fifth-degree felony, one

count of Possession of Cocaine, in violation of R.C. §2925.11(A) & (C)(4)(a), a fifth degree

felony, and one count of Failure of Sexually Oriented Offender to Notify of Change of

Address, in violation of R.C. §2950.05(F)(1), a first-degree felony. The indictment also

included Sexually Violent Predator specifications on the Rape and Kidnapping counts, Sexual

Motivation specifications on the Kidnapping counts, and Forfeiture specifications on the drug

possession counts.

{¶3} A statement of the facts underlying Appellant's criminal convictions is not

necessary to our resolution of this appeal. A complete review of the facts may be found in our

opinion at State v. Ramsey, 2015-Ohio-4812 (5th Dist.), appeal not allowed. [Ramsey I].

{¶4} On July 21, 2014, Appellant filed a motion requesting the Sexually Violent

Predator and Sexual Motivation specifications be tried to the court. Pursuant to a Judgment

Entry filed on July 31, 2014, the trial court granted Appellant’s motion.

{¶5} The matter proceeded to trial by jury and Appellant was found guilty as charged

on all counts.

{¶6} On August 12, 2014, the trial court heard evidence on the Sexually Violent

Predator specifications attached to the Rape and Kidnapping counts and the Sexual

Motivation specifications attached to the Kidnapping counts.

{¶7} By Judgment Entry filed August 20, 2014, the trial court filed Findings of Fact

and Conclusions of Law, finding Appellant guilty of the Sexual Motivation specification

attached to Count II (Kidnapping) and guilty of the Sexually Violent Predator specifications

attached to Count I (Rape) and Count II (Kidnapping). The trial court found Appellant not

guilty of the Sexual Motivation specifications as attached to Count III (Kidnapping) and

found the Sexually Violent Predator specification did not apply to this count.

{¶8} The trial court sentenced Appellant to an aggregate prison sentence of twentyfive (25) years to life. Appellant filed a direct appeal of his convictions and sentence in Ramsey

I, supra, in which this Court overruled his six assignments of error and affirmed his convictions

and sentence. See State v. Ramsey, 2015-Ohio-4812, ¶ 1 (5th Dist.).

{¶9} On September 25, 2023, Appellant filed a motion with the trial court "to dispose

of pending specifications in open court proceedings and to provide defendant with a final

appealable order." Specifically, Appellant argued the trial court did not find him guilty or not

guilty of the specifications attached to Count III of the indictment, Kidnapping.

{¶10} By Judgment Entry filed October 2, 2023, the trial court overruled Appellant’s

motion, noting its "Findings of Fact and Conclusions of Law Regarding Specifications" filed

August 14, 2014, stated Appellant was found not guilty of the Sexual Motivation specification

and further found the Sexually Violent Predator specification did not apply to the charge

absent the finding of a sexual motivation.

{¶11} Appellant appealed the October 2, 2023, decision to this Court. See State v.

Ramsey, 2024-Ohio-2000, ¶ 8 (5th Dist.) [Ramsey II]. In that appeal this Court found Appellant

was barred by the doctrine of res judicata from raising any alleged errors in any manner other

than direct appeal. Ramsey II at ¶19.

{¶12} On April 28, 2026, Appellant filed a “motion to vacate sexually violent

predator specification and to correct sentence not authorized by law.”

{¶13} On May 8, 2026, the trial court denied Appellant’s motion.

{¶14} Appellant now appeals the May 8, 2026, decision, raising the following errors

for review:

I. THE TRIAL COURT ERRED BY APPLYING RES JUDICATA

TO BAR REVIEW OF A RECORD BASED STATUTORY CHALLENGE

DIRECTED TO THE LEGAL INTERPRETATION EXPRESSLY

ADOPTED IN THE MAY 8, 2026 ORDER, WHERE THAT

INTERPRETATION WAS NEVER RAISED, LITIGATED, OR DECIDED

IN ANY PRIOR APPEAL. THE ERROR APPEARS IN THE MAY 8, 2026

ORDER OVERRULING MOTION TO VACATE, APPENDIX A, PAGES

3 THROUGH 5.

II. THE TRIAL COURT ERRED AS A MATTER OF LAW BY

INTERPRETING R.C. 2971.01(H) IN A MANNER THAT TREATED THE

RETROSPECTIVE EVIDENTIARY FACTORS IN SUBSECTION (H)(2)

AS AUTOMATICALLY SUFFICIENT TO SATISFY THE

INDEPENDENT FUTURE LIKELIHOOD REQUIREMENT IN

SUBSECTION (H)(1). THE ERROR APPEARS IN THE MAY 8, 2026

ORDER, APPENDIX A, PAGES 4 THROUGH 5, AND IN THE AUGUST

20, 2014 FINDINGS, APPENDIX B, PAGE 2.

III. THE TRIAL COURT ERRED BY BASING THE FUTURELIKELIHOOD DETERMINATION ON PRIOR CONVICTIONS ALONE,

THEREBY FAILING TO ARTICULATE AN INDEPENDENT

PREDICTIVE DETERMINATION AND DEPRIVING THE PHRASE

"LIKELY TO ENGAGE IN THE FUTURE" OF OPERATIVE MEANING.

THE ERROR APPEARS IN THE AUGUST 20, 2014 FINDINGS,

APPENDIX B, PAGE 2, AND IS REAFFIRMED IN THE MAY 8, 2026

ORDER APPENDIX A, PAGE 5.

IV. THE TRIAL COURT'S ERROR INFECTED THE LEGAL

STANDARD GOVERNING PROOF OF THE ENHANCEMENT ITSELF,

BECAUSE THE COURT TREATED EVIDENCE THAT MAY TEND TO

INDICATE FUTURE LIKELIHOOD AS LEGALLY EQUIVALENT TO

PROOF OF FUTURE LIKELIHOOD BEYOND A REASONABLE

DOUBT. THE ERROR APPEARS IN THE MAY 8, 2026 ORDER,

APPENDIX A, PAGE 5, AND IN THE AUGUST 20, 2014 FINDINGS,

APPENDIX B, PAGE 2.

V. THE TRIAL COURT IMPROPERLY TREATED STATE V.

RAMSEY, 2024-OHIO-2000, AS FORECLOSING REVIEW EVEN

THOUGH THAT DECISION ADDRESSED WHETHER COUNT III

SPECIFICATIONS WERE RESOLVED AND JOURNALIZED, NOT

WHETHER THE COUNTS I AND II SVP SPECIFICATIONS WERE

IMPOSED UNDER THE CORRECT STATUTORY FRAMEWORK. THE

ERROR APPEARS IN THE MAY 8, 2026 ORDER, APPENDIX A, PAGES

2 THROUGH 5.

I, II, III, IV and V

{¶15} In each of his assignments of error, Appellant challenges the trial court’s verdict

on the specifications following the bench trial. We shall therefore address the assignments of

error simultaneously.

{¶16} Upon review, we find the trial court’s August 20, 2014, Judgment Entry was a

final appealable order and the error assigned herein could have been included in Appellant’s

direct appeal. We therefore find Appellant’s arguments are barred by the doctrine of res

judicata.

{¶17} The doctrine of res judicata provides any issue that could have been raised on

direct appeal, and was not, is barred in later proceedings and not subject to review. State v.

Saxon, 2006-Ohio-1245, ¶ 16. Because any non-void sentencing errors are required to be raised

on direct appeal, Appellant is barred by the doctrine of res judicata from raising any alleged

errors in any manner other than direct appeal. State v. Hill, 2016-Ohio-1214, ¶ 16 (5th Dist.).

{¶18} Appellant’s assignments of error are overruled.

{¶19} The judgment of the Richland County Court of Common Pleas is affirmed.

{¶20} Costs to Appellant.

By: Hoffman, P.J.

Baldwin, J. and

Montgomery, J. concur.