The Ohio Sixth Appellate District Court recently issued a decision impacting the sentencing of Samuel Peoples, affirming much of his lengthy prison term but ordering the trial court to correct a technical oversight regarding how it documented its reasons for imposing consecutive sentences. In a consolidated appeal stemming from three separate cases, Peoples was sentenced to an aggregate prison term of 17.5 to 20 years following guilty pleas. While the appellate court found no issue with the trial court’s determination that Peoples was competent to stand trial, it flagged an inconsistency between the oral findings made during sentencing and the written judgment entries.
The Charges and the Plea Deal
Peoples faced a serious slate of charges across three trial court cases. The most severe charges arose from case No. CR 202402010, which included aggravated burglary, felonious assault (with a firearm specification), strangulation, and weapons charges related to an incident involving his ex-girlfriend. The State alleged that Peoples broke into her home, strangled her, and then shot at her as she fled into the street.
In the other two cases (CR 202402074 and CR 202402297), Peoples faced charges including burglary, attempted burglary, and failure to comply with police signals.
Before trial, Peoples underwent psychiatric evaluations, which led to a formal competency hearing. The evaluator ultimately opined that Peoples understood the proceedings and could assist his defense, noting indications that Peoples might be “feigning or exaggerating of symptoms.” Despite some intellectual and reading comprehension difficulties, the court found him competent.
Peoples subsequently entered into a plea agreement, pleading guilty to lesser or modified charges, including aggravated burglary (without the firearm spec) and felonious assault (with the firearm spec) in the first case, attempted burglary in the second, and failure to comply in the third.
During the plea colloquy, Peoples initially expressed only “50/50” satisfaction with his attorney, prompting the judge to pause proceedings for a recess to ensure the plea was voluntary and intelligent. After conferring with counsel, Peoples confirmed his satisfaction, and the court accepted his pleas.
Aggravated Sentencing Justified by Conduct
At sentencing, the State detailed the violent nature of the offenses, emphasizing the strangulation and shooting incident, as well as a subsequent police chase where Peoples allegedly discarded the firearm used in the earlier crime.
The trial court ultimately imposed significant consecutive sentences across the three cases, resulting in the 17.5 to 20-year aggregate term. The court explicitly stated at the hearing that consecutive sentences were necessary to protect the public, punish Peoples, and that the harm caused was so great that a single term could not reflect the seriousness of his conduct. These findings aligned with the requirements under Ohio Revised Code section 2929.14(C)(4).
The Technical Flaw: Incomplete Written Findings
Peoples appealed, raising two main arguments: first, that the consecutive sentence findings were unsupported by the record given his mental health history, and second, that he was not competent to stand trial.
The appellate court swiftly rejected the competency argument. Citing the expert evaluation which noted potential malingering and the defendant’s own assurances during the plea hearing, the court found no abuse of discretion in the trial court’s finding that Peoples was competent.
However, the court found merit in the first assignment of error, though not on the grounds Peoples argued. The appellate panel reviewed the trial court’s reasoning under the standard set by R.C. 2953.08(G)(2), which requires modification or vacation of a sentence only if the findings are “clearly and convincingly” unsupported by the record.
The court confirmed that the trial judge *did* make all the necessary findings orally during the sentencing hearing. The problem, the court noted, lay in the written sentencing entries. The entries failed to fully incorporate a specific part of the required finding under R.C. 2929.14(C)(4)(b)—specifically, the finding that the offenses were committed as part of a course of conduct where the harm was so great no single term would suffice.
“Because the trial court made the required findings at the sentencing hearing but inadvertently omitted part of the (C)(4)(b) findings from its judgment entries,” the appellate court ruled, “we must reverse and remand this case to the trial court for the limited purpose of entering *nunc pro tunc* entries to reflect what actually occurred in open court.”
The court stressed that this failure was a clerical mistake, not a legal error in the sentencing itself. Furthermore, the court found that the underlying facts—including strangulation, shooting, and fleeing police while armed—were more than sufficient to support the imposition of consecutive sentences, meaning the sentence was not “clearly and convincingly unsupported by the record.”
In summary, the aggregate sentence stands, but the case is sent back to the trial court solely to amend the paperwork to accurately reflect the findings already made on the record.