To Enhance Later Domestic Violence Offense, Must State Produce 'Judgments of Conviction' for Prior Offenses?
Court Asked Whether Journal Entries Must Comply With Requirements of Crim.R. 32(C)
State of Ohio v. Jeffrey L. Gwen, Case no. 2011-0632
Ninth District Court of Appeals (Summit County)
ISSUE: In order to use a defendant's prior domestic violence convictions to enhance a subsequent domestic violence charge against him, must the state prove the prior offenses by producing journal entries that meet all the requirements for a "judgment of conviction" under Criminal Rule 32(C)?