State v. Orenich

Citations

• 2025 Ohio 1367

Syllabus

R.C. 2945.75; lifetime driver's license suspension; Crim.R. 52(B); plain error; R.C. 2921.331; R.C. 4510.02; Crim.R. 11; guilty plea; prior conviction. Judgment affirmed. The appellant is unable to show that the trial court erred in imposing the mandatory lifetime driver's license suspension. When a prior conviction enhances the punishment for committing a subsequent crime but does not raise the degree of the offense, the prior conviction does not have to be included in the indictment because it is not an essential element of the subsequent crime. Thus, the State was not required to provide appellant notice of his prior conviction because the prior conviction is only relevant as a sentencing enhancement; it is not an element of the offense charged under R.C. 2921.331.