The Ohio Court of Appeals has upheld the sentencing of Marquis Bollar in a recent decision that affects his conviction for involuntary manslaughter and related charges. The court ruled on August 27, 2026, affirming the Stark County Common Pleas Court's denial of Bollar's petition for post-conviction relief. This ruling is significant as it reinforces the legal framework surrounding firearm specifications and sentencing in Ohio.
Marquis Bollar was convicted for the shooting death of Erica Delong on August 13, 2019. He faced multiple charges, including felony murder, involuntary manslaughter, felonious assault, and having weapons while under disability. The Stark County Grand Jury indicted him on four counts, each with a firearm specification. Following a plea deal, Bollar pleaded guilty to involuntary manslaughter, felonious assault, and having weapons while under disability, with the state dismissing the murder charge.
The case reached the Ohio Court of Appeals after Bollar filed a petition for post-conviction relief, claiming that his sentencing involved unlawful stacking of firearm specifications. He argued that because the counts of involuntary manslaughter and felonious assault merged for sentencing, he should only face one firearm specification. However, the trial court denied his petition on the grounds that it was untimely and successive, as he had already raised similar issues in previous appeals.
The court's ruling emphasized that Bollar's arguments were not sufficient to overturn the prior decisions. Judge William B. Hoffman, along with Judges Craig R. Baldwin and Kevin W. Popham, noted that Bollar's claims did not satisfy the requirements for post-conviction relief under Ohio law. The court stated, "The trial court was required by R.C. 2929.14(B)(1)(g) to sentence Bollar to the two most serious firearm specifications that accompanied his felony guilty pleas." This ruling reinforces the principle that firearm specifications can be treated separately from the underlying offenses, even if those offenses merge.
The impact of this ruling is significant for Bollar and others in similar situations. It clarifies the application of Ohio's laws regarding firearm specifications and sentencing. The court's decision confirms that defendants cannot simply merge charges to avoid multiple firearm specifications if they are guilty of multiple felonies. This case could set a precedent for future cases involving similar legal arguments, as it highlights the importance of adhering to statutory requirements when it comes to sentencing.
Looking ahead, Bollar may still have options for appeal, although the court's ruling makes it clear that his current arguments have been exhausted. The court's decision may also influence other cases involving post-conviction relief in Ohio, particularly those related to firearm specifications. As the legal landscape continues to evolve, it remains to be seen how this ruling will affect future defendants facing similar charges.