State v. Bryant
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The Supreme Court reversed the judgment of the court of appeals upholding Defendant's sentence, holding that a defendant's display of disrespect toward a trial court is not a permissible sentencing factor that the court may consider under Ohio Rev. Code 2929.11 and 2929.12.
The trial court in this case increased Defendant's prison sentence by six years in response to Defendant's misbehavior while reacting to the length of a previously-imposed prison sentence. The court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant's outburst or other courtroom misbehavior may not result in an increased sentence for the underlying crime; and (2) the six-year increase in Defendant's sentence was contrary to law.
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