In State v. Walker, the Court of Appeals of Ohio reviewed the convictions of Neomanni Walker, who represented himself at trial after repeatedly rejecting court-appointed counsel, invoking sovereign citizen rhetoric. The court affirmed most of his convictions but reversed one due to insufficient evidence.
On February 4, 2024, Neomanni Walker was involved in a shooting outside the home of Gerald Brown in Cincinnati, Ohio. Earlier that day, Walker, Ayla Belcher, and Kendall Alexander were seen on surveillance video at multiple gas stations using stolen credit cards to purchase fuel. Walker paid for other people’s gas in exchange for cash or electronic transfers.
Later that morning, Brown discovered his car had been broken into. Soon after, Belcher drove Walker and Alexander back to Brown’s residence. Surveillance footage and eyewitness testimony confirmed that Alexander, after being encouraged by Walker—who allegedly yelled “Bust at him, cuz”—fired at Brown, striking him in the thigh. Multiple shots also struck Brown’s home.
Walker was indicted on two counts of felonious assault, one count of improperly discharging a firearm into a habitation, and one count of having weapons while under disability (WUD). In a separate indictment, he was also charged with WUD, receiving stolen property, and theft, after police recovered a stolen firearm from his residence.
Walker informed the trial court he wished to represent himself, stating that having counsel presented a “conflict of interest.” During the required Crim.R. 44 colloquy, Walker refused to sign a waiver of counsel and repeatedly stated he did not consent to the court’s jurisdiction. He referred to himself as “the authorized representative to the defendant” and said he would “do no business with [the court’s] corporation.” The trial court conducted an extensive inquiry, explaining the charges, potential penalties, trial procedures, and disadvantages of self-representation. Despite the court’s repeated recommendations that Walker retain counsel, he insisted on proceeding pro se. Standby counsel was appointed and present throughout trial.
At trial, Brown testified about being shot in front of his home. Neighbor Sarah Stockton’s surveillance footage captured Walker and Alexander running from the scene. Belcher identified Walker in the footage and confirmed he had encouraged Alexander to shoot. She also testified that Walker congratulated Alexander afterward. Surveillance from a nearby gas station showed Walker with Belcher and Alexander earlier that day.
Detective Alexander McCoy from the Cincinnati Police Department investigated the scene and testified about the ballistic evidence. Shell casings recovered from the scene matched a stolen firearm later found in Walker’s home. Nefertiti Warner, the gun’s lawful owner, reported it stolen in Hamilton County. Additional evidence linked Walker to stolen credit cards used that same day.
Walker did not present a defense, choosing to rest on the presumption of innocence. He objected only to the admission of certain video evidence.
Walker was convicted of both counts of felonious assault and improperly discharging a firearm at or into a habitation. He was found not guilty on the firearm specifications and one WUD charge. He received an aggregate sentence of 16–20 years in prison for these convictions.
In the second case, Walker was convicted of WUD, receiving stolen property, and theft, and received an additional 5.5-year consecutive sentence. The jury found him guilty on all counts, but the appellate court later reversed the conviction for receiving stolen property due to lack of evidence that Walker knew the firearm was stolen.
Appeal and Ruling
Walker raised four assignments of error on appeal:
Waiver of Counsel: Despite Walker’s use of sovereign citizen language and refusal to sign a written waiver, the court found he knowingly, intelligently, and voluntarily waived his right to counsel. The court cited precedent involving similar behavior from other sovereign citizen defendants.
Venue: The court held that the State proved venue beyond a reasonable doubt. Witnesses identified the location as Cincinnati, and the case was investigated by local police and prosecuted in Hamilton County.
Receiving Stolen Property: The court agreed with the State’s concession that there was insufficient evidence Walker knew the handgun was stolen. That conviction was reversed.
Improper Discharge of a Firearm: Walker argued that his statement “Bust at him, cuz” did not prove complicity in discharging a firearm at a habitation. The court disagreed, finding that since the victim was standing in front of his home, the statement and resulting gunfire supported the conviction under Ohio law.
The appellate court affirmed all convictions except for receiving stolen property. Walker’s claims, including those rooted in sovereign citizen ideology, did not succeed in reversing the majority of his convictions.
Source: Court of Appeals of Ohio, First Appellate District, Hamilton County | March 21, 2025 | 2025-Ohio-975