State v. Willan
Annotate this CaseAfter a jury trial, Defendant was found guilty of sixty-eight counts, including one first-degree-felony count of engaging in a pattern of corrupt activity in violation of Ohio's Racketeer-Influenced and Corrupt Organizations (RICO) statute. Defendant was sentenced to a total prison term of sixteen years after the trial court determined that a mandatory ten-year prison term was required under Ohio Rev. Code 2929.14(D)(3)(a) for the corrupt-activity count. The court of appeals (1) affirmed the guilty verdicts for the corrupt-activity count and three of the predicate violations but reversed most of the remaining guilty verdicts; and (2) vacated the mandatory ten-year prison term imposed for the corrupt-activty count, finding section 2929.14(D)(3)(a) ambiguous as to whether the mandatory ten-year term applied to Defendant. The Supreme Court reversed, holding that a mandatory ten-year prison term is required pursuant to section 2929.14(D)(3)(a) if the court imposing a sentence for a felony finds the offender is guilty of corrupt activity with the most serious offense in the pattern of corrupt activity being a felony in the first degree.
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