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State v. Malloy

2026-08-31

Summary

Holding. The trial court's 10-month prison sentence was affirmed because the court properly considered the mandatory sentencing factors, was not obligated to follow the parties' joint sentencing recommendation, and adequately explained its decision based on Malloy's criminal history and recidivism concerns.

Timothy Malloy pleaded guilty to receiving stolen property, a fifth-degree felony, under a plea agreement in which the prosecutor recommended community control. At sentencing, the trial court declined to follow the joint recommendation and instead imposed a 10-month prison sentence. The court cited Malloy's extensive prior criminal record, multiple probation violations, and the fact that he committed the current offense while subject to post-release control from an earlier conviction. The court concluded that imprisonment was necessary to reflect the seriousness of the offense and protect the public.

Malloy appealed, arguing the trial court erred by disregarding the agreed sentencing recommendation and by failing to adequately explain why community control would be inappropriate. On appeal, the court applied the stringent standard for reviewing felony sentences under state law, which limits appellate authority to modifying sentences that lack record support or are contrary to law. The appellate court found no error because the trial court explicitly considered all required sentencing factors and was not bound by the parties' non-binding recommendation.

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

Key issues

  • whether a trial court may reject a jointly recommended sentence in a plea agreement
  • sufficiency of sentencing explanation when court considers statutory factors
  • standard of appellate review for felony sentencing decisions
  • effect of defendant's prior probation violations and post-release control status on sentencing discretion

Procedural posture

Malloy appealed the trial court's December 15, 2025 sentencing judgment to the Ohio Court of Appeals, Eleventh Appellate District.

Authorities cited

Opinion

majority opinion

[Cite as State v. Malloy, 2026-Ohio-3393.]

IN THE COURT OF APPEALS OF OHIO

ELEVENTH APPELLATE DISTRICT

ASHTABULA COUNTY

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

Plaintiff-Appellee,

Criminal Appeal from the

- vs - Court of Common Pleas

TIMOTHY C. MALLOY,

Trial Court No. 2025 CR 00017

Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: August 31, 2026

Judgment: Affirmed

April R. Grabman, Ashtabula County Prosecutor, and Dane R. Hixon, Assistant Prosecutor, 25 West Jefferson Street, Jefferson, OH 44047 (For Plaintiff-Appellee).

Margaret Brunarski, Ashtabula County Public Defender; Tia N. Jackson and Phillip L. Heasley, Assistant Public Defenders, Ashtabula County Public Defender’s Office, 22 East Jefferson Street, Jefferson, OH 44047 (For Defendant-Appellant).

MATT LYNCH, P.J.

{¶1} Appellant, Timothy C. Malloy, appeals the December 15, 2025 entry of the

Ashtabula County Court of Common Pleas sentencing him to serve 10 months in prison

following his negotiated plea of guilty to one count of Receiving Stolen Property. Finding

no reversible error, we affirm the trial court’s judgment.

{¶2} Malloy was initially indicted on two counts of Receiving Stolen Property, in

violation of R.C. 2913.51(A) and (C), pertaining to a motor vehicle (Count One) and a

debit card (Count Two). On November 20, 2025, pursuant to a plea agreement, Malloy

pleaded guilty to Count Two, a fifth-degree felony, and the State dismissed Count One, a fourth-degree felony. The written plea agreement, signed by Malloy, states, “I understand

that any recommendation of sentence to the Court by the State is not binding in any way

on the Court and that any sentence to be imposed is in the sole discretion of the Court.”

At the plea hearing, the prosecutor told the court that the State had agreed to make a

community control recommendation at sentencing. The court later asked Malloy, “Do you

understand that the Court is not bound to any agreed sentence between you and the

State of Ohio?” Malloy responded, “Yes, ma’am.”

{¶3} On December 15, 2025, following a presentence investigation, the trial court

held a sentencing hearing. Defense counsel asked the court to follow through with the

parties’ joint recommendation for community control, and the prosecutor maintained that

the State would abide by the terms of the agreement. The court reviewed the presentence

report, outlining Malloy’s lengthy history of prior convictions and probation violations. The

court stated it had considered the purposes and principles of the sentencing statutes,

including the overriding purposes of punishing the offender and protecting the public from

future crime. As it relates to the recidivism and seriousness factors, the court found that

Malloy has a substantial prior criminal record, a history of criminal convictions and

probation violations, has not been law abiding for several years, and committed the

instant offense while on post-release control or parole in a prior case. For these reasons,

despite the low-level felony in this case, the court stated it could not follow the joint

recommendation for community control. The court found community control “would

demean the seriousness of the conduct in this case and its impact upon the victim and

would not adequately protect the public. Therefore, a sentence of imprisonment is

commensurate with the seriousness of the defendant’s conduct and a prison sentence

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does not place an unnecessary burden on the State and promotes rehabilitation.” The

court then sentenced Malloy to a nonmandatory prison term of 10 months, with credit for

time served.

{¶4} The sentencing entry was journalized on December 15, 2025. The court

stated therein that it had considered the record, information presented by or on behalf of

Malloy and the prosecuting attorney, any victim information provided by the State, and

Malloy’s ability to pay financial sanctions, as well as the purposes and principles of

sentencing and the seriousness and recidivism sentencing factors. This appeal followed.

{¶5} Malloy raises one assignment of error for our review:

{¶6} “The trial court erred by exceeding its discretion in sentencing defendant.”

{¶7} Our standard of review for felony sentencing is found in R.C. 2953.08(G)(2):

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

division (B) or (D) of section 2929.13, division (B)(2)(e) or (C)(4) of section

2929.14, or division (I) of section 2929.20 of the Revised Code, whichever,

if any, is relevant;

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

{¶8} Our jurisdiction to review the sentencing factors in R.C. 2929.11 and

2929.12 is limited under R.C. 2953.08(G)(2)(b). State v. Brunson, 2022-Ohio-4299, ¶ 69.

“Under that provision, the appellate court cannot modify or vacate a sentence based on

its view that the sentence is not supported by the record under R.C. 2929.11 and

2929.12.” Id., citing State v. Jones, 2020-Ohio-6729, ¶ 39. “Nothing in R.C.

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2953.08(G)(2) permits an appellate court to independently weigh the evidence in the

record and substitute its judgment for that of the trial court concerning the sentence that

best reflects compliance with R.C. 2929.11 and 2929.12.” Jones at ¶ 42.

{¶9} “When sentencing, a ‘trial court is not required to give any particular weight

or emphasis to a given set of circumstances; it is merely required to consider the statutory

factors in exercising its discretion.’ State v. Delmanzo, 2008-Ohio-5856, ¶ 23 (11th Dist.).

A sentencing court fulfills its duty when it states that it has considered the factors under

R.C. 2929.11 and R.C. 2929.12. State v. DeLuca, 2021-Ohio-1007, ¶ 18 (11th Dist.).”

State v. Hackathorn, 2023-Ohio-410, ¶ 8 (11th Dist.).

{¶10} In support of his assignment of error, Malloy contends that the trial court

disregarded the clear agreement between the parties for a sentence of community control

and disregarded the clear mandates of R.C. 2929.11 when it imposed a 10-month prison

sentence. Malloy argues that the court merely recited statutory language and never

indicated specifically why the public needed protection from him or why the goal of

effective rehabilitation could not have been achieved through the less-restrictive sanction

of community control.

{¶11} However, we are without any authority to independently weigh mitigating

factors under R.C. 2929.12, Jones at ¶ 42, and the trial court fulfilled its duty in this regard

by stating at the sentencing hearing and in its sentencing entry that it had considered all

factors under R.C. 2929.11 and 2929.12. See Hackathorn at ¶ 14. Accord State v. Pace,

2025-Ohio-5291, ¶ 12 (11th Dist.). The court specifically noted Malloy’s lengthy criminal

history and probation violations, as well as the fact that he committed the present offense

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while on post-release control in a prior case. On balance, the court found that Malloy was

not amenable to a community control sanction in this case.

{¶12} Moreover, it is well established that “trial courts may reject plea agreements

and that they are not bound by a jointly recommended sentence.” State v. Underwood,

2010-Ohio-1, ¶ 28. “‘A trial court does not err by imposing a sentence greater than “that

forming the inducement for the defendant to plead guilty when the trial court forewarns

the defendant of the applicable penalties, including the possibility of imposing a greater

sentence than that recommended by the prosecutor.”’” State ex rel. Duran v. Kelsey,

2005-Ohio-3674, ¶ 6, quoting State v. Buchanan, 2003-Ohio-4772, ¶ 13 (5th Dist.),

quoting State v. Pettiford, 2002 WL 652371, *3 (12th Dist. Apr. 22, 2002). Accord State

v. Butler, 2026-Ohio-318, ¶ 11 (11th Dist.).

{¶13} Malloy signed a Written Plea of Guilty that expressly states, “I understand

that any recommendation of sentence to the Court by the State is not binding in any way

on the Court and that any sentence to be imposed is in the sole discretion of the Court.”

At the plea hearing, the trial court asked Malloy, “Do you understand that the Court is not

bound to any agreed sentence between you and the State of Ohio?” Malloy answered,

“Yes, ma’am.” Thus, nothing in this record supports the conclusion that Malloy was not

sufficiently made aware that the parties’ joint sentencing recommendation was not binding

upon the court.

{¶14} The trial court was under no obligation to follow the joint sentencing

recommendation, and we cannot substitute our judgment for that of the trial court in its

application of the sentencing factors. Accordingly, appellant’s sole assignment of error is

without merit.

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{¶15} The judgment of the Ashtabula County Court of Common Pleas is affirmed.

JOHN J. EKLUND, J.,

ROBERT J. PATTON, J.,

concur.

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Case No. 2026-A-0006

JUDGMENT ENTRY

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

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

Ashtabula 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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Case No. 2026-A-0006