The Ohio Court of Appeals recently upheld a trial court's ruling regarding court costs imposed on James D. Ketchum, who was convicted of theft and breaking and entering. This decision, delivered on June 30, 2026, affects Ketchum and others in similar situations regarding the clarity of court costs. The ruling clarifies the distinction between mandatory and non-mandatory costs in Ohio law.
Ketchum faced a three-count indictment filed by the Wood County Grand Jury on September 5, 2024. The charges included grand theft of a motor vehicle, theft of tools and accessories, and breaking and entering. The indictment stemmed from allegations that Ketchum deprived Hunger Hydraulics USA of property and services without consent.
On December 6, 2024, Ketchum changed his plea from not guilty to guilty for two of the counts: theft and breaking and entering. The state agreed to dismiss the grand theft charge as part of a plea deal. The trial court sentenced him on January 30, 2025, to two years of community control for each count, with specific conditions imposed.
However, Ketchum later violated the terms of his community control by failing to appear for an appointment and was subsequently found in violation on August 1, 2025. The court imposed a 12-month confinement for each count, to be served concurrently but consecutive to any existing sentences he was serving.
During the sentencing for the community control violation, the trial court ordered Ketchum to pay court costs, but did not specify the exact amounts or types of costs. This led Ketchum to appeal, arguing that the lack of clarity made the order too vague and contrary to Ohio law.
The Ohio Court of Appeals, led by Judge Thomas J. Osowik, reviewed Ketchum's case and the trial court's decision. The court noted that Ketchum's appeal focused on the imposition of court costs without specific details. The court referenced a previous case, State v. Greene, which addressed similar issues regarding mandatory and non-mandatory costs.
The court ruled, "Like Greene, in this case, the record establishes no separate determination by the trial court regarding non-mandatory costs under R.C. 2947.23."
The court ultimately found no error in the trial court's imposition of court costs, stating that the costs were mandatory under Ohio Revised Code. The ruling emphasized that mandatory costs do not require a determination of the defendant's ability to pay, while non-mandatory costs do.
This ruling has significant implications for Ketchum and others in similar situations. It clarifies that courts in Ohio can impose mandatory costs without specifying the exact amounts or types, as long as they are in accordance with the law. This decision may influence how future cases are handled regarding court costs, especially for those who might challenge their imposition.
Moving forward, Ketchum's case may not be the last to address the issue of court costs in Ohio. The ruling sets a precedent that could affect defendants facing similar situations in the future. However, details about any potential appeals or related cases were not available in the court filing.