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State v. Lewis

2026-08-31

Summary

Holding. The Court of Appeals affirmed the trial court's judgment, holding that Lewis did not comply with the statutory notice requirements to invoke speedy-trial protections, that the trial court's findings supporting consecutive sentences were supported by the record and legal, and that no sentencing error occurred.

Roderick Lewis appealed his conviction for felony drug possession charges, raising three claims of error. First, Lewis argued that the trial court should have dismissed the case because he did not receive a speedy trial under Ohio's statutory framework protecting incarcerated defendants. The court rejected this argument, finding that Lewis failed to properly invoke the speedy-trial protection by neglecting to include his Trumbull County case number in his request for disposition to the warden—he had only requested disposition of a separate Franklin County case. Because Lewis's own failure to provide complete information prevented the statutory process from starting, the trial court retained jurisdiction and properly denied the motion to dismiss. Second and third, Lewis challenged the imposition of consecutive sentences, arguing they were unsupported and illegal. The court found that the trial judge clearly articulated required statutory findings at sentencing: Lewis had an extensive criminal history with eleven prior felony convictions, had been rejected for rehabilitative programming, posed a high risk of reoffending, and was on probation when he committed the current offenses. These findings satisfied the legal standards for consecutive sentencing and were supported by the record. The trial judge's decision remained within the lawful sentencing range for the charges.

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

Key issues

  • Compliance with statutory notice requirements under R.C. 2941.401 to invoke speedy-trial protection for incarcerated defendants
  • Whether the trial court made legally sufficient findings to impose consecutive sentences
  • Whether the record supported the trial court's findings regarding defendant's criminal history and dangerousness

Procedural posture

Roderick Lewis appealed his conviction and consecutive sentence imposed by the Trumbull County Court of Common Pleas to the Ohio Court of Appeals, Eleventh District.

Authorities cited

Opinion

majority opinion

[Cite as State v. Lewis, 2026-Ohio-3399.]

IN THE COURT OF APPEALS OF OHIO

ELEVENTH APPELLATE DISTRICT

TRUMBULL COUNTY

STATE OF OHIO, CASE NO. 2026-T-0006

Plaintiff-Appellee,

Criminal Appeal from the

- vs - Court of Common Pleas

RODERICK L. LEWIS,

Trial Court No. 2025 CR 00090

Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: August 31, 2026

Judgment: Affirmed

Dennis Watkins, Trumbull County Prosecutor, and Charles L. Morrow, Assistant Prosecutor, Administration Building, Fourth Floor, 160 High Street, N.W., Warren, OH 44481 (For Plaintiff-Appellee).

Martin Yavorcik, 940 Windham Court, Suite 7, Youngstown, OH 44512 (For DefendantAppellant).

MATT LYNCH, P.J.

{¶1} Appellant, Roderick L. Lewis, appeals from the final judgment of conviction

and sentence entered by the Trumbull County Court of Common Pleas. Lewis challenges

the denial of his motion to dismiss on speedy trial grounds and the imposition of

consecutive sentences. We affirm.

{¶2} A grand jury indicted Lewis on one count of Aggravated Possession of

Drugs (methamphetamine), in violation of R.C. 2925.11(A) & (C)(1)(a), and one count of

Possession of Drugs (cocaine), in violation of R.C. 2925.11(A) & (C)(4)(a), both fifthdegree felonies. Lewis initially pleaded not guilty but later entered a plea of no contest to the Indictment. The trial court accepted the plea and found Lewis guilty. Following a

presentence investigation, the court sentenced Lewis to the maximum prison term of 12

months on each count, to be served consecutively, for an aggregate term of 24 months.

{¶3} Lewis now appeals, raising three assignments of error for review.

Speedy Trial

{¶4} As his first assignment of error, Lewis contends the trial court erred in

denying his motion to dismiss under R.C. 2941.401, thereby violating his statutory right

to a speedy trial and losing jurisdiction over his case as a result.

{¶5} “R.C. 2941.401 delineates how an Ohio prisoner is to enforce his

constitutional right to a speedy trial on an untried indictment.” State v. Williams, 2023-Ohio-3647, ¶ 1. If a speedy trial violation under R.C. 2941.401 occurs, then a trial court

has no further jurisdiction over the matter. State v. Dillon, 2007-Ohio-3617, ¶ 23. We

review alleged speedy trial violations under R.C. 2941.401 de novo. See Williams at ¶ 8.

{¶6} R.C. 2941.401 provides, in relevant part:

When a person has entered upon a term of imprisonment in a correctional

institution of this state, and when during the continuance of the term of

imprisonment there is pending in this state any untried indictment,

information, or complaint against the prisoner, the prisoner shall be brought

to trial within one hundred eighty days after the prisoner causes to be

delivered to the prosecuting attorney and the appropriate court in which the

matter is pending, written notice of the place of the prisoner’s imprisonment

and a request for a final disposition to be made of the matter, except that

for good cause shown in open court, with the prisoner or the prisoner’s

counsel present, the court may grant any necessary or reasonable

continuance. The request of the prisoner shall be accompanied by a

certificate of the warden or superintendent having custody of the prisoner,

stating the term of commitment under which the prisoner is being held, the

time served and remaining to be served on the sentence, the amount of

good time earned, the time of parole eligibility of the prisoner, and any

decisions of the adult parole authority relating to the prisoner.

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The written notice and request for final disposition shall be given or sent by

the prisoner to the warden or superintendent having custody of the prisoner,

who shall promptly forward it with the certificate to the appropriate

prosecuting attorney and court by registered or certified mail, return receipt

requested. If the appropriate prosecuting attorney and agency having

custody of the prisoner have previously agreed, then the written notice,

request, and certificate may be sent by electronic mail or facsimile, in lieu

of registered mail or certified mail.

If the action is not brought to trial within the time provided, subject to

continuance allowed pursuant to this section, no court any longer has

jurisdiction thereof, the indictment, information, or complaint is void, and the

court shall enter an order dismissing the action with prejudice.

(Emphasis added.)

{¶7} “In its plainest language, R.C. 2941.401 grants an incarcerated defendant

a chance to have all pending charges resolved in a timely manner, thereby preventing the

state from delaying prosecution until after the defendant has been released from his

prison term.” State v. Hairston, 2004-Ohio-969, ¶ 25. “The statute triggers the 180-day

speedy-trial clock to start running when the prisoner ‘causes to be delivered’ to the

prosecuting attorney and the appropriate court a written notice of the place of his

imprisonment and a request for a final disposition of the pending matter.” Williams at ¶ 1.

“A prisoner satisfies the ‘causes to be delivered’ requirement in R.C. 2941.401 by

providing written notice of the place of his imprisonment and a request for final disposition

to the warden of the institution where he is incarcerated.” Id. at ¶ 18. The prisoner’s

compliance with R.C. 2941.401 triggers the warden’s statutory duty to promptly forward

the notice and request, along with the certificate of the warden or superintendent having

custody of the prisoner, to the appropriate prosecuting attorney and court by registered

or certified mail. Id. at ¶ 17.

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{¶8} When a warden fails to act as prescribed under R.C. 2941.401, “whether

intentionally, inadvertently, or otherwise, the consequences of that failure should inure to

the state, on whose behalf the warden acts.” Id. On the other hand, “‘[w]here the inmate

forwards incomplete, inaccurate, misleading or erroneous information, any subsequent

errors by the warden or superintendent will be imputed to the inmate.’” State v. Colon,

2010-Ohio-2326, ¶ 23 (5th Dist.), quoting State v. Gill, 2004-Ohio-1245, ¶ 17 (8th Dist.).

Accord State v. Jarvis, 2023-Ohio-4229, ¶ 6 (9th Dist.).

{¶9} In his motion to dismiss, filed May 7, 2025, Lewis alleged that he “was in

the custody of the Trumbull County Sheriff awaiting a preliminary hearing on the present

case when he was transported to Lorain Correctional Institution” and that he “requested

that notices of availability be filed upon his arrival in ODRC custody, as can be seen in

the notice that was actually delivered to the Franklin County Court of Common Pleas.”

Lewis claimed that the “180-day time for bringing the case to trial expired between

October 20 and October 23, 2024.”

{¶10} Attached to Lewis’s motion are two unverified and unattested exhibits.

“Exhibit A” includes the following: (1) a letter on ODRC letterhead dated April 23, 2024,

addressed to “prosecuting attorney” and signed by “T Rosales, Record Office,” advising

that Lewis is imprisoned on “Trumbull 2023CR682” and requesting early disposition of

case No. 23CR5450; (2) “Notice of Untried Indictments, Information or Complaint and of

Rights to Request Disposition,” notifying Lewis that he has a detainer in case No.

23CR5450, signed by Lewis on April 26, 2024, and requesting early disposition under

R.C. 2941.401; (3) “Notice of Place of Imprisonment and Request for Disposition of

Indictments, Information or Complaints,” addressed to Franklin County Common Pleas

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Prosecuting Attorney, signed by Lewis on April 26, 2024, and requesting final disposition

be made for case No. 23CR5450. “Exhibit B” includes an undated “Notice to Offender,”

informing Lewis that he has an active warrant with the Trumbull County Sheriff in Warren

Municipal Court case No. 23CRA002345. (This case was subsequently bound over to

the Trumbull County Court of Common Pleas and assigned case No. 2025 CR 00090,

which is the subject of the instant appeal.)

{¶11} The trial court overruled Lewis’s motion to dismiss, finding Lewis did not

comply with the procedure set forth in R.C. 2941.401. Upon de novo review, we agree

with the State’s position that the exhibits submitted with Lewis’s motion reveal that he did

not “cause to be delivered” his written notice and request for final disposition in this case.

{¶12} Notably absent from Lewis’s motion to dismiss is any written notice of the

place of his imprisonment and any request for final disposition to the warden of the

institution where he was incarcerated that includes the case number of the Trumbull

County case at issue here (i.e., Common Pleas case No. 2025 CR 00090 or Warren

Municipal case No. 23CRA002345). The exhibits submitted in support of Lewis’s motion

to dismiss reflect that he only submitted a request for final disposition of the Franklin

County Case. Lewis’s failure to request final disposition of this case is imputed to him,

not the warden, and the speedy trial clock in this case never started for purposes of R.C.

2941.401. See Jarvis, 2023-Ohio-4229, at ¶ 10 (9th Dist.); Colon, 2010-Ohio-2326, at

¶ 23 (5th Dist.); Gill, 2004-Ohio-1245, at ¶ 17 (8th Dist.). Consequently, this case is

distinguishable from Williams, 2023-Ohio-3647, where the defendant “satisfied his every

obligation under” R.C. 2941.401, and from Dillon, 2007-Ohio-3617 (cited by appellant in

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support of his assignment of error), where the warden initially failed to deliver the

indictment and notice to the defendant.

{¶13} Lewis’s first assignment of error is without merit.

Consecutive Sentences

{¶14} In his second assignment of error, Lewis contends the trial court’s

imposition of consecutive sentences is unsupported by the record. In his third assignment

of error, Lewis contends the trial court imposed a sentence contrary to law.

{¶15} “Under Ohio’s statutory sentencing scheme, there is a presumption that a

defendant’s multiple prison sentences will be served concurrently, R.C. 2929.41(A),

unless certain circumstances not applicable in this case apply, see, e.g., R.C.

2929.14(C)(1) through (3), or the trial court makes findings supporting the imposition of

consecutive sentences under R.C. 2929.14(C)(4).” State v. Jones, 2024-Ohio-1083,

¶ 11. R.C. 2929.14(C)(4) provides:

If multiple prison terms are imposed on an offender for convictions of

multiple offenses, the court may require the offender to serve the prison

terms consecutively if the court finds that the consecutive service is

necessary to protect the public from future crime or to punish the offender

and that consecutive sentences are not disproportionate to the seriousness

of the offender’s conduct and to the danger the offender poses to the public,

and if the court also finds any of the following:

(a) The offender committed one or more of the multiple offenses while the

offender was awaiting trial or sentencing, was under a sanction imposed

pursuant to [R.C. 2929.16, 2929.17, or 2929.18], or was under post-release

control for a prior offense.

(b) At least two of the multiple offenses were committed as part of one or

more courses of conduct, and the harm caused by two or more of the

multiple offenses so committed was so great or unusual that no single

prison term for any of the offenses committed as part of any of the courses

of conduct adequately reflects the seriousness of the offender’s conduct.

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(c) The offender’s history of criminal conduct demonstrates that consecutive

sentences are necessary to protect the public from future crime by the

offender.

“Though ‘a trial court is required to make the findings mandated by R.C. 2929.14(C)(4) at

the sentencing hearing and incorporate its findings into its sentencing entry, . . . it has no

obligation to state reasons to support its findings. Nor is it required to give a talismanic

incantation of the words of the statute, provided that the necessary findings can be found

in the record and are incorporated into the sentencing entry.’” Jones at ¶ 11, quoting

State v. Bonnell, 2014-Ohio-3177, ¶ 37.

{¶16} R.C. 2953.08(G) instructs appellate courts reviewing the imposition of

consecutive sentences as follows:

(2) The court hearing an appeal under [R.C. 2953.08(A), (B), or (C)] shall

review the record, including the findings underlying the sentence or

modification given by the sentencing court.

The appellate court may increase, reduce, or otherwise modify a sentence

that is appealed under this section or may vacate the sentence and remand

the matter to the sentencing court for resentencing. The appellate court’s

standard for review is not whether the sentencing court abused its

discretion. The appellate court may take any action authorized by this

division if it clearly and convincingly finds either of the following:

(a) That the record does not support the sentencing court’s findings under

[R.C. 2929.14(C)(4)];

(b) That the sentence is otherwise contrary to law.

“R.C. 2953.08(F) requires an appellate court to review the entire trial-court record,

including any oral or written statements made to or by the trial court at the sentencing

hearing, and any presentence, psychiatric, or other investigative report that was

submitted to the court in writing before the sentence was imposed. R.C. 2953.08(F)(1)

through (4).” Jones at ¶ 12.

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{¶17} “The standard to be applied is the standard set forth in the statute: an

appellate court has the authority to increase, reduce, otherwise modify, or vacate a

sentence only after it has reviewed the entire trial-court record and ‘clearly and

convincingly f[ound] either . . . [t]hat the record does not support the sentencing court’s

findings under [certain statutes]’ or ‘[t]hat the sentence is otherwise contrary to law,’ R.C.

2953.08(G)(2).” Id. at ¶ 13; see also State v. Marcum, 2016-Ohio-1002, ¶ 22.

{¶18} Here, the transcript of Lewis’s sentencing hearing clearly shows that the

trial court made the findings necessary to impose consecutive sentences, and Lewis has

not demonstrated that those findings were not supported by the record. As noted by the

trial court, “The Defendant has an extensive criminal history of arrests and convictions.

The Defendant has eleven prior felony convictions. The Defendant has served eleven

prior prison sentences based on those felony convictions. And he was rejected by

NEOCAP and is at a high risk to re-offend. The Defendant was on probation when the

instant offense was committed.” The trial court specifically found that “consecutive

sentences are necessary to protect the public from future crime and that consecutive

sentences are not disproportionate to the seriousness of the offender’s conduct and to

the danger the offender poses to the public.” In addition, the trial court explicitly stated

that Lewis’s “history of criminal conduct demonstrates that consecutive sentences are

necessary to protect the public from future crime by him.”

{¶19} At sentencing, Lewis’s counsel recounted his history of drug addiction and

requested community control sanctions. On appeal, Lewis notes the instant offenses

involved small quantities of narcotics and caused no harm to any victim. However, the

trial court made the findings necessary for the discretionary imposition of consecutive

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prison sentences under R.C. 2929.14(C)(4), and those findings are not clearly and

convincingly unsupported by the record, R.C. 2953.08(G)(2), and are memorialized in the

sentencing entry. Moreover, the imposed sentence was within the statutory range for

fifth-degree felonies, R.C. 2929.14(A)(5), and the trial court expressly considered the

purposes and principles of felony sentencing, including the relevant seriousness and

recidivism factors.

{¶20} Lewis’s second and third assignments of error are without merit.

{¶21} The judgment of the Trumbull County Court of Common Pleas is affirmed.

JOHN J. EKLUND, J.,

ROBERT J. PATTON, J.,

concur.

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JUDGMENT ENTRY

For the reasons stated in the opinion of this court, appellant’s assignments of error

are without merit. It is the judgment and order of this court that the judgment of the

Trumbull County Court of Common Pleas is affirmed.

Costs to be taxed against appellant.

PRESIDING JUDGE MATT LYNCH

JUDGE JOHN J. EKLUND,

concurs

JUDGE ROBERT J. PATTON,

concurs

THIS DOCUMENT CONSTITUTES A FINAL JUDGMENT ENTRY

A certified copy of this opinion and judgment entry shall constitute the mandate

pursuant to Rule 27 of the Ohio Rules of Appellate Procedure.

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