The Second Appellate District Court of Ohio has upheld the convictions of Anthony J. Davis on charges related to dangerous dogs. The court’s decision, issued on October 3, 2025, affirms the rulings of the Miami County Municipal Court. Davis, representing himself in the appeal, raised several arguments, all of which were rejected by the appellate court.
Background of the Case
The case involved two separate cases from the Miami County Municipal Court that were combined for the appeal. Davis was found guilty on multiple counts related to his failure to properly contain two dogs. The specific charges included:
* Failure to obtain a dangerous dog registration
* Failure to control and confine a dangerous dog
* Failure to report a designated-dangerous dog as loose
* Failure to confine or control a dog
The trial court sentenced Davis in one case (2025 CRB 00084) to 30 days in jail, with 25 days suspended, and a five-year community control term. A condition of his community control was that he not be allowed to have any animals in his home. In the second case (2025 CRB 00133), Davis received a similar sentence: 30 days in jail, with all but 30 days suspended, and a five-year community control term, also prohibiting him from keeping animals.
Davis’s Arguments on Appeal
Davis, acting without a lawyer (pro se), presented three main arguments to the appellate court.
Due Process Claim
Davis’s first argument was that the trial court violated his right to due process. He claimed the court’s actions lacked sufficient notice and violated his constitutional rights. The appellate court cited the Fourteenth Amendment of the U.S. Constitution and Section 16, Article I of the Ohio Constitution, which guarantee procedural due process. The court stated that the basic requirements of due process are “notice and an opportunity to be heard.”
However, the appellate court rejected this argument. They noted that Davis did not argue that the laws under which he was convicted were unclear. The court also pointed out that Davis was properly notified of the charges and had an attorney representing him during the trial. Since Davis did not provide transcripts of the trial proceedings, the court presumed that Davis was given the opportunity to present evidence, cross-examine witnesses, and be heard. Therefore, the court found no evidence of a due process violation.
Sentencing Challenges
Davis’s second argument focused on the sentences imposed by the trial court. He claimed that the penalties were excessive and unjustified, including the restriction on pet ownership.
The appellate court reviewed the legal standards for misdemeanor sentencing in Ohio. The court explained that the goal of misdemeanor sentencing is to protect the public and punish the offender. When determining a sentence, the court must consider factors like the impact on the victim and the need to rehabilitate the offender. The court also noted that, in general, the trial court has discretion in determining the appropriate sentence.
The appellate court found that Davis had been charged with repeat offenses. Because Davis did not provide transcripts of the sentencing hearing, the court had to presume that the trial court had considered all relevant factors. The court concluded that there was no basis to find the trial court abused its discretion in sentencing.
Sufficiency of Evidence
Davis’s third argument was that the charges against him were not supported by enough evidence. He contended that the evidence did not justify the severity of the charges or the penalties.
The appellate court dismissed this argument as well. Without the trial and sentencing transcripts, the court had to assume that the trial court’s decisions were valid. Therefore, the court ruled that Davis’s argument regarding the sufficiency of the evidence failed.
Court’s Decision
Because Davis’s arguments were unsuccessful, the Second Appellate District Court of Ohio affirmed the Miami County Municipal Court’s judgments.