The Ohio Court of Appeals has affirmed the sentencing of Marquis L. Bollar, who appealed a decision from the Stark County Court of Common Pleas. The court ruled on August 20, 2026, that Bollar's arguments regarding his sentence were without merit. This ruling affects Bollar, who is serving a lengthy prison sentence for serious offenses, including involuntary manslaughter and felonious assault.
The case, State v. Bollar (2026CA00065), has garnered attention due to its implications on how firearm specifications are handled in relation to merged offenses. The court's decision reinforces the legal standards for sentencing in Ohio, particularly concerning the application of firearm specifications.
Background
Marquis Bollar was indicted on October 17, 2019, by a Stark County Grand Jury on multiple charges, including felony murder, involuntary manslaughter, felonious assault, and having weapons under disability. Each charge included a firearm specification. On March 6, 2020, the state dismissed the felony murder charge, and Bollar pleaded guilty to the remaining counts.
During sentencing, Bollar's defense argued that the charges of involuntary manslaughter and felonious assault should merge for sentencing purposes. However, the state contended that two of the firearm specifications needed to run consecutively. The trial court ultimately sentenced Bollar to a minimum of 20 years in prison, which included a mandatory three years for the firearm specifications.
The Ruling
In its recent ruling, the Ohio Court of Appeals upheld the trial court's decision regarding Bollar's sentence. The court stated, "The determination of guilt based upon his guilty pleas to each offense survived the trial court's merger of the felonious assault and involuntary manslaughter offenses." The judges on the panel included Andrew J. King, William B. Hoffman, and Robert G. Montgomery.
The court also noted that Bollar's arguments concerning the legality of his sentence had already been addressed in a previous appeal. The court explained that the law of the case doctrine prevented the trial court from revisiting the sentencing issue. The ruling emphasized that Bollar's motion for postconviction relief was untimely and barred by res judicata, which prohibits relitigating issues that were or could have been raised in prior proceedings.
Impact
This ruling has significant implications for Bollar and others facing similar situations in Ohio. It clarifies that once a court has ruled on a matter, particularly regarding sentencing, the same arguments cannot be raised again in subsequent motions. This decision reinforces the importance of timely appeals and the constraints of the postconviction relief process.
Furthermore, the ruling establishes a precedent regarding the handling of firearm specifications in cases where offenses are merged. The court's interpretation of Ohio Revised Code 2929.14(B)(1)(g) indicates that offenders may face consecutive sentences for firearm specifications even if the underlying offenses are considered allied offenses.
What's Next
Bollar's options for further legal recourse appear limited. The court's decision can be appealed to the Ohio Supreme Court, but the likelihood of the court agreeing to hear the case is uncertain. There are currently no related cases pending that would directly influence this ruling.