State v. Bryant
| Decision Date | 07 June 2022 |
| Docket Number | 2020-0599 |
| Parties | The State of Ohio, Appellee, v. Bryant, Appellant. |
| Court | Ohio Supreme Court |
Submitted April 14, 2021
Appeal from the Court of Appeals for Lake County, No. 2019-L-024 2020-Ohio-438.
Charles E. Coulson, Lake County Prosecuting Attorney, and Jennifer A. McGee, Assistant Prosecuting Attorney, for appellee.
Timothy Young, Ohio Public Defender, and Max Hersch, Assistant Public Defender, for appellant.
{¶ 1} In this discretionary appeal from a judgment of the Eleventh District Court of Appeals, we consider whether the appellate court erred by affirming the trial court's judgment increasing appellant Manson Bryant's prison sentence by six years in response to Bryant's reaction to the length of a previously imposed prison sentence. We hold that the Eleventh District erred, and we reverse the judgment affirming the trial court's judgment increasing Bryant's sentence. If a defendant's outburst or other courtroom misbehavior causes a significant disruption that obstructs the administration of justice, that behavior may be punishable as contempt of court. See R.C. 2705.01. The behavior, however, may not result in an increased sentence for the underlying crime.
{¶ 2} Being a trial-court judge is not an easy job. In the criminal-justice context, trial-court judges are tasked with, among other things, (1) hearing the sordid facts of a case, (2) acting as gatekeepers by deciding what evidence is admissible, (3) protecting the federal and state constitutional rights of the accused, (4) determining whether the accused is guilty beyond a reasonable doubt in a bench trial, (5) deciding whether to overturn a jury's finding of guilt when the defense moves for a judgment of acquittal based on insufficient evidence of guilt, and (6) imposing a sentence that fulfills the purposes and principals of sentencing set forth in the Revised Code when the accused is found guilty. Against this backdrop, we expect a lot from trial-court judges. We expect them to (1) provide a safe space for victims who come before the court to tell their stories, (2) have sympathy and compassion for those victims, (3) maintain control over their courtrooms to assure the safety of those in attendance and maintain an atmosphere of respect for everyone who comes into the courtroom, (4) fairly, impartially, and dispassionately mediate disputes between opposing parties over discovery, evidentiary issues, and other litigation matters, and (5) treat those who are accused of crimes and those who are convicted of crimes with courtesy, dignity, and respect. Essentially, we ask trial-court judges to appraise wrongdoing, attribute blame, absolve the innocent, and punish the wrongdoer, all while creating an atmosphere that facilitates justice and fairness through neutral and careful decision-making. This is no easy task. And like all jobs, it is one that is impossible to do perfectly.
{¶ 3} To have any type of honest and meaningful discussion about why the Eleventh District's judgment should be reversed and Bryant's 28-year sentence vacated-and a 22-year prison sentence reimposed-it is important to acknowledge that the very act of presiding over a criminal case, with all its accompanying pressures and responsibilities, often exacts an emotional toll on the trial-court judge. Even the most experienced, even-keeled, and unflappable trial-court judge is subject, every day, to stressors that may generate a range of emotions. In a perfect world, every trial-court judge would be able to control his or her emotions and not let those emotions get in the way of sound and just decision-making. But we do not live in a perfect world. The best that we can do as a society is to give trial-court judges the tools and support they need to help them productively funnel their emotions and vast powers over the life and liberty of individuals into just outcomes. The best we can do as reviewing courts-because we have a broader perspective on the wide-reaching impacts of individual trial-court decisions and the better position to neutrally evaluate those decisions-is to correct errors in judgment and provide guidance. But to do these things, we need to start by acknowledging what is uncomfortable to acknowledge: that trial-court judges do get offended and angry, that anger clouds judgment, and that clouded judgment often results in unjust outcomes. The record in this case demonstrates that fundamentally, this is what happened when the trial-court judge added an additional six years of incarceration to Bryant's prison sentence after Bryant had an emotional outburst upon being sentenced to 22 years in prison.
{¶ 4} In October 2018, a Lake County grand jury indicted Bryant on seven criminal counts related to his involvement, along with a codefendant, in an armed burglary of an occupied trailer home. Counts One and Two charged Bryant with aggravated burglary, a felony of the first degree, in violation of R.C. 2911.11(A)(1) (Count One) and R.C. 2911.11(A)(2) (Count Two). The remaining counts were: Count Three, aggravated robbery, a felony of the first degree, in violation of R.C. 2911.01(A)(1); Count Four, kidnapping, a felony of the first degree, in violation of R.C. 2905.01(A)(2); Count Five, abduction, a felony of the third degree, in violation of R.C. 2905.02(A)(2); Count Six, having a weapon while under a disability, a felony of the third degree, in violation of R.C. 2923.13(A)(2); and Count Seven, carrying concealed weapons, a felony of the fourth degree, in violation of R.C. 2923.12(A)(2). Each count contained a forfeiture specification pursuant to R.C. 2941.1417 and 2981.04. Counts One through Five included one-and three-year firearm specifications pursuant to R.C. 2941.141 and 2941.145.
{¶ 5} Bryant pleaded not guilty to all counts in the indictment and the case proceeded to a jury trial on Counts One through Five and part of Count Seven. The portion of Count Seven that Bryant elected to have tried to the jury was renumbered to Count Six ("jury-count six"). Bryant waived his right to a jury trial on Count Six and the remaining part of Count Seven, electing to have a bench trial on those counts. The jury found Bryant guilty of Counts One through Five and jury-count six. The trial court found him guilty of Counts Six and Seven.
{¶ 6} The matter proceeded to sentencing on March 1, 2019. The court began the sentencing hearing by explaining the jury's findings of guilt and how it would handle several merger issues. The court merged the two counts of aggravated burglary (Counts One and Two), the abduction and kidnapping counts (Counts Four and Five), and the two counts of carrying a concealed weapon (jury-count six and Count Seven). The court also merged the abduction and kidnapping counts (Counts Four and Five) with the-aggravated robbery count (Count Three) as well as the one-year and three-year firearm specifications for Counts One and Three. After merger, the trial court stated that Bryant would be sentenced on Count One, aggravated burglary; Count Three, aggravated robbery; Count Six, having weapons while under a disability; and Count Seven, carrying concealed weapons.
{¶ 7} Before sentencing Bryant, the court gave Bryant's attorney, Bryant, and the assistant prosecutor a chance to make a statement. Bryant's attorney began by distinguishing Bryant's conduct from that of his codefendant's, in that Bryant was an "aider and abettor," as opposed to his codefendant, who was the principal actor in the commission of the burglary. Bryant's attorney reminded the court that Bryant's codefendant was sentenced to a 12-year prison term, and the attorney asked the court to sentence Bryant to a 10-year prison term.
{¶ 8} Thereafter, Bryant was given the chance to speak directly to the court. He stated:
Your Honor, I know you [are] very well aware of my history. I made a lifetime of bad decisions. And those bad decisions has caused pain to a lot of people in my family. For that I am truly sorry. Most of my bad decisions have been driven by my addiction to drugs, and to do whatever I can to continue to get high. My ability to stay clean has me to spend most of my life in prison. There's no way for a person to live-that's no way for a person to live. And it's not how I want to finish my life. Despite the circumstances of my upbringing, I understand that I can't continue to blame others for my actions and my behaviors. I have become jaded towards the legal system. By having this trial, was honest and open eye for me. I have never gone through trial before. I have a new found respect for the efforts of the attorneys, judges, jurors, and goal in living as an, as giving an accused person a opportunity to have a case heard. That's all anyone can ask. I am thankful for the opportunity afforded by the court, by the day in court, and I respect the decision that the juries has made. I alone have the power to end the cycle of incarceration, and all I ask is for you to give me an opportunity to still make something out of my life, sir. I don't want to die in prison, sir. I'm not a bad person, sir. I do have a drug problem. I've been in front of you multiple times. I respect you. And I respect your decision that you make today.
{¶ 9} After Bryant made his remarks, the trial court allowed the state to present its position regarding Bryant's sentence. The state opposed Bryant's request for leniency, disagreeing that Bryant was merely an aider and abettor in the commission of the offenses. The state also pointed to Bryant's extensive criminal history and previous probation and postrelease-control violations as reasons for imposing a lengthier sentence than the sentence that had been imposed on Bryant's...
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