When Neither Party Requests a Presentence Report at Trial, May an Appeals Court Reverse the Sentence Based on the Absence of That Report?
Christopher Richmond v. State of Ohio, Case no. 2012-2156
Eighth District Court of Appeals (Cuyahoga County)
ISSUE: Is it appropriate, without the most exigent circumstances, for an appellate court to disturb a trial court's sentence of community control sanctions in a felony case when neither party requests a presentence investigation report?