State v. Guyton

Citations

• 2022 Ohio 2962

Syllabus

CONSTITUTIONAL LAW/CRIMINAL — SENTENCING — REAGAN TOKES LAW: Defendant cannot demonstrate that the indefinite sentencing scheme embodied in the Reagan Tokes Law is unconstitutional beyond a reasonable doubt: the law does not violate the separation-of-powers doctrine, because the judiciary imposes the sentence that is enforced by the Ohio Department of Rehabilitation and Correction (\ODRC\), an executive branch agency, using a presumptive release date the law does not violate substantive-due-process rights or the right to equal protection under the law, because the indefinite sentencing scheme creating a presumptive release date that affects only those convicted of non-life-sentence felony offenses of the first and second degree is rationally related to the state's goal in reducing recidivism for serious offenders by incentivizing good conduct in prison as observed by those overseeing the prisons and finally, where the statute directing ODRC action that affects the deprivation of an offender's liberty interest does not preclude notice to an offender and specifically contemplates a hearing, it must be read as one with the constitutional requirements of procedural due process, and therefore, a set of circumstances exists under which the challenged statute satisfies procedural due process. [But see DISSENT: The Reagan Tokes Law facially violates procedural due process because the General Assembly failed to include basic procedural-due-process protections in the legislation.]