State v. Daniel
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The Supreme Court affirmed the decision of the court of appeals in this criminal case, holding that it does not violate the separation of powers doctrine to tie the judge's ability to reduce the registration period for a person convicted of arson to a recommendation from executive branch officials.
In 2012, the General Assembly passed a law codified at Ohio Rev. Code 2909.13(A) establishing a registry of people convicted of arson-related crimes that applied to those convicted of arson or aggravated arson, as well as those convicted of a related attempt or conspiracy or complicity offense. At issue was Ohio Rev. Code 2909.15(D)(2)(b), which provides a limited exception for the lifetime-registration requirement. Defendant in this case pleaded guilty to a single count of arson, for which he was required to register annually for life. At sentencing, challenged the constitutionality of the reduced-registration provision. The trial court denied the challenge, and the court of appeals affirmed. The Supreme Court affirmed, holding that there is no separation of powers violation within Ohio's arson offender registration scheme.
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