Why Sentencing Law Isn’t Always Straightforward: Lessons from the Ohio Supreme Court in State v. Logan

In State v. Logan, decided on May 21, 2025, the Ohio Supreme Court clarified a critical—and often misunderstood—area of criminal sentencing law: when a defendant is convicted of a felony that includes a firearm specification, prison time is not optional. The case involved Jadyn Logan, who pled guilty to attempted having weapons under disability, a third-degree felony, along with a one-year firearm specification. The trial court imposed a one-year prison term for the firearm specification but allowed Logan to serve two years of community control (probation) for the felony itself. At first glance, this may seem like a reasonable compromise. However, the Supreme Court concluded it was legally impermissible.

The central issue before the Court was whether Ohio Revised Code section 2929.13(F)(8) required a mandatory prison sentence for the felony offense itself—not just the firearm enhancement. The statute states that if a defendant is convicted of a felony “with respect to which” a firearm specification is imposed, the court must impose a prison term. The defense argued that the prison mandate applied only to the firearm specification. But the Supreme Court disagreed. In a 6–1 decision, the justices held that the statute’s language and the broader sentencing scheme make clear: when a firearm specification attaches to a felony, prison is mandatory for the underlying felony, not just the specification.

The Court reasoned that firearm specifications are not standalone offenses—they are sentencing enhancements that attach to an actual felony conviction. Accordingly, allowing a court to impose prison time for the enhancement but probation for the felony would defy the structure of Ohio’s sentencing laws, which require a court to impose either prison or community control for each felony offense—not a mixture of both. This ruling resolved conflicting decisions from lower courts across the state and reaffirmed that trial courts cannot use creative sentencing to avoid the General Assembly’s mandatory prison terms.

Justice Brunner dissented, warning that the majority’s interpretation expanded sentencing obligations beyond the plain text of the statute. She emphasized judicial restraint and the need to respect legislative clarity. But the majority’s opinion will now guide sentencing courts throughout Ohio.

The implications of this decision are significant. First and foremost, it reinforces the importance of understanding how firearm specifications impact felony sentencing. A defendant who agrees to a plea deal involving a firearm specification must now expect—and receive—a prison sentence for the felony itself, regardless of what is negotiated for the enhancement. This is not a detail that can be glossed over during plea discussions or overlooked at sentencing.

For defendants, this ruling highlights the risks of navigating felony charges without well-informed legal guidance. It is not uncommon for courts or attorneys to misunderstand—or misapply—statutory sentencing mandates. When that happens, defendants may receive sentences that are later overturned, leading to appeals, resentencing, and legal uncertainty. These outcomes can be avoided when a knowledgeable defense attorney is involved early in the process, ensuring that every plea agreement and sentencing entry complies with Ohio law from the start.

Ultimately, State v. Logan is a reminder that sentencing is not just about what “feels” fair or practical in a courtroom—it is about what the law requires. And when prison is mandatory, no amount of compromise can substitute for a clear understanding of the statute. At our firm, we stay up to date on developments like these so that our clients can make informed decisions, avoid unnecessary delays, and protect their rights at every stage of the criminal process.

Disclaimer: The content on this blog is provided for general informational purposes only and does not constitute legal advice. Reading or using this information does not create an attorney-client relationship. Laws change over time and vary by jurisdiction; you should not rely solely on this content for decisions regarding your specific situation. If you need legal advice or representation, please consult a qualified Ohio criminal defense attorney to discuss the particulars of your case.