Columbus v. Davis

Citations

• 2021 Ohio 2114

Syllabus

Defendant not entitled to court-appointed counsel on failure to register a dog in violation of R.C. 955.21 because complaint did not include penalty-enhancing language set forth in R.C. 955.99(E)(1), which would have included the potential for imprisonment. Because the potential penalty for a third-degree misdemeanor violation of Columbus City Code 2327.11 includes the possibility of imprisonment, defendant had a right to jury trial pursuant to R.C. 2945.17(A) defendant filed a timely written jury demand which was never waived therefore, conviction for that offense reversed and the matter remanded for retrial. Defendant's convictions for violations of R.C. 955.39 not supported by sufficient evidence city concedes that it failed to present evidence of a rabies quarantine order issued under R.C. 955.26. Convictions for failure to register a dog in violation of R.C. 955.21, and failure to confine a dog in violation of R.C. 955.22 supported by sufficient evidence and not against the manifest weight of the evidence.