State v. Wright - Appeal Dismissed as Moot
Summary
The Ohio Court of Appeals dismissed an appeal in State v. Wright as moot because the appellant had completed his prison sentence. The court cited the completion of the sentence as rendering the assignments of error unaddressable.
What changed
The Ohio Court of Appeals, in the case of State v. Wright, has dismissed an appeal filed by the appellant, Todd Wright. The dismissal is based on the principle of mootness, as Wright has completed his prison sentence. Consequently, the court found that it could not address the merits of his assignments of error, effectively ending the appellate process for these specific charges.
This ruling means that the legal challenges Wright attempted to raise on appeal are no longer considered justiciable due to the fulfillment of his sentence. Regulated entities, particularly those involved in criminal justice proceedings, should note that appeals may be dismissed if the underlying sentence or issue has been resolved. This emphasizes the importance of timely appeals and the potential for cases to become moot if not pursued with due diligence.
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March 20, 2026 Get Citation Alerts Download PDF Add Note
State v. Wright
Ohio Court of Appeals
- Citations: 2026 Ohio 962
- Docket Number: L-25-00102, L-25-00103
Judges: Osowik
Syllabus
Per Osowik, J., Appeal is dismissed. The merits of appellant's assignments cannot be addressed because the completion of his prison sentence sanction renders his appeal moot.
Combined Opinion
by [Thomas J. Osowik](https://www.courtlistener.com/person/8121/thomas-j-osowik/)
[Cite as State v. Wright, 2026-Ohio-962.]
IN THE COURT OF APPEALS OF OHIO
SIXTH APPELLATE DISTRICT
LUCAS COUNTY
State of Ohio Court of Appeals No.L-25-00102,
L-25-00103
Appellee
Trial Court No. CR0202401981,
v. CR0202402298
Todd Wright DECISION AND JUDGMENT
Appellant Decided: March 20, 2026
Julia R. Bates, Prosecuting Attorney, and
Lorrie J . Rendle, Assistant Prosecuting Attorney, for appellee.
Patricia Horner, for appellant.
OSOWIK, J.
Procedural History
{¶ 1} This is a consolidated appeal of two separate cases from the Lucas County
Court of Common Pleas.
{¶ 2} In case No. CR 24-2298, appellant, Todd Wright, was charged with
trafficking in cocaine, a violation of R.C. 2925.03, a third -degree felony (Count 1),
possession of cocaine, a violation of R.C. 2925.l l(A)(C)(4)(c) a third-degree felony
(Count 2) and driving under suspension, a violation of R.C. 4510.l l(A)and(D)(F) and
(G) a first-degree misdemeanor (Count 3).
{¶ 3} In case No. CR 2024-1981, he was charged with Count 1 trafficking in
cocaine, violation of R.C. 2925.03(A)(2) and (C)(4)(b) a fourth-degree felony,
Count 2 possession of cocaine a violation of 2925.11, a fourth-degree felony, and
assault, Count 3, a fourth-degree felony and a violation of R.C.
2903.13(A)(C)(l)(C)(5)(a).
{¶ 4} On October 2, 2024, appellant was before a Lucas County Common Pleas
Court judge for a fugitive warrant from the State of Georgia. Appellant was taken into
custody and remained detained until he was sentenced on the two criminal felony cases.
{¶ 5} Ultimately, on February 11, 2025 in case No. CR 24-2298 , appellant plead
to a lesser included offense of trafficking in cocaine, a fourth-degree felony, Count 1,
and a violation of 2925.03(A)(2) and (C)(4(c). Wright was sentenced on February 27,
2025, to 12 months in prison, the remaining 2 counts were dismissed.
{¶ 6} On February 11, 2025, for case No. CR24-1981 appellant plead no contest
to count 2, possession of cocaine, a violation of R.C. 2925.1 l(A) and (C)(4)(a) a felony
of the fith degree. He was sentenced also on February 27, 2025, to 6 months at ODRC
and the other 2 counts were dismissed.
2.
{¶ 7} In both cases, appellant filed a “Motion to Correct Jail Time Credit.” On
April 15, 2025, the motions in each case were denied by the trial court. It is from these
judgments that Wright appeals. Those two cases were consolidated by this court.
Assignment of Error
{¶ 8} Wright presents a single assignment of error for our review:
The trial court erred in denying appellant jail time credit.
{¶ 9} More specifically, Wright argues that the trial court committed reversible
error when it denied appellant credit for time he was detained on a fugitive warrant for a
case that arose while appellant was working on resolving the Ohio felony charges and
for which he had posted surety bonds.
Suggestion of Mootness
{¶ 10} On January 14, 2026, the State filed its brief. In that brief, the State
attached an exhibit. That exhibit is ostensibly from the website of the Ohio Department
of Rehabilitation and Corrections. It represents that the appellant herein, Todd L. Wright
was released from incarceration on January 13, 2026. As a result of Wright’s release
from incarceration, the State argues that his appeal is moot.
{¶ 11} Wright did not file a reply brief nor did he file a response to the State's
suggestion of mootness.
Law and Analysis
{¶ 12} We have consistently held that because an appeal concerning jail-time
credit involves the appellant's sentence length, not the underlying conviction, the
3.
appellant suffers no collateral disability or loss of rights that can be addressed by an
appellate court once the sentence has been served. State v. Russell, 2023-Ohio-3547, ¶ 10
(6th Dist.), citing State v. Ambriez, 2005-Ohio-5877, ¶ 10 (6th Dist.). Therefore, although
an offender may seek review of a trial court's refusal to grant jail-time credit by filing an
appeal of the court's judgment, such an appeal is rendered moot once the appellant is
released. State v. Solomon, 2025-Ohio-1378, ¶ 6-9 (6th Dist.).
{¶ 13} Here, Wright did not appeal his judgment of conviction, and his appeal in
the instant case concerns only the issue of whether he was entitled to jail-time credit. As
such, it is now moot, in light of his release.
Conclusion
{¶ 14} For the foregoing reasons, Wright’s appeal of the April 15, 2025 judgment
of the Lucas County Court of Common Pleas is dismissed. Appellant is ordered to pay
the costs of this appeal pursuant to App.R. 24. The judgement of the trial court is moot.
Judgment dismissed.
4.
State of Ohio v. Todd Wright
Case Nos.: L-25-00102, L-25-00103
Trial Court Case Nos.: CR0202401981, CR0202402298
A certified copy of this entry shall constitute the mandate pursuant to App.R. 27.
See also 6th Dist.Loc.App.R. 4.
Thomas J. Osowik, P.J.
JUDGE
Christine E. Mayle, J.
JUDGE
Myron C. Duhart, J.
CONCUR. JUDGE
This decision is subject to further editing by the Supreme Court of
Ohio’s Reporter of Decisions. Parties interested in viewing the final reported
version are advised to visit the Ohio Supreme Court’s web site at:
http://www.supremecourt.ohio.gov/ROD/docs/.
5.
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