State v. Ramirez

Citations

• 2025 Ohio 1542

Syllabus

Hybrid sentences, community-control sanction, child-support order, invited-error doctrine, motion to withdraw a guilty plea. Ramirez appeals the journal entry sentencing him to 11 months in prison for attempted unlawful sexual conduct with a minor and requiring him to pay child support while incarcerated. The child-support order is a community-control sanction, which cannot be imposed along with a prison term for a felony offense. Ramirez did not \invite\ this sanction under the invited-error doctrine because it was not part of the settlement agreement the parties presented to the court. The court also did not abuse its discretion in denying Ramirez's motion to withdraw his guilty plea. The 11-month sentence was less than the maximum authorized for a fifth-degree felony, and the record did not support Ramirez's claims that the court was swayed by emotion, failed to adequately consider his request, or that he was under the influence of medication during his sentencing hearing.