Left: Manson Bryant seen in a booking photo (via Ohio Department of Rehabilitation and Correction). Right: Bryant seen in court objecting to the sentence issued to him in March 2019 (via YouTube screengrab).
An Ohio man who called the judge who sentenced him to more than two decades in prison “racist as f**k” during a courtroom outburst shouldn’t have had additional prison time tacked on to his decades-long sentence, according to the state’s highest court.
Manson Bryant, 35, was convicted by a jury in 2018 on robbery, kidnapping, and weapons charges relating to an armed burglary of an occupied trailer home. He and a co-defendant were accused of crawling through the home’s window and holding the resident at gunpoint while robbing him.
At Bryant’s sentencing hearing in March 2019, he was given the chance to speak on his own behalf.
“I made a lifetime of bad decisions,” Bryant told Lake County Common Pleas Court Judge Eugene Lucci at the time. “And those bad decisions has caused pain to a lot of people in my family. For that, I am truly sorry.”
Bryant said that many of his decision were driven by drug addiction, and that he wanted to stay clean. He also praised Lucci and the criminal justice system as a whole.
“I have never gone through trial before,” he said at his hearing. “I have a newfound respect for the efforts of the attorneys, judges, jurors, and goal in living as an, as giving an accused person a opportunity to have a case heard. That’s all anyone can ask. I am thankful for the opportunity afforded by the court, by the day in court, and I respect the decision that the juries has made.”
Bryant pleaded with Lucci for an opportunity to “still make something” out of his life.
“I don’t want to die in prison, sir,” Bryant said. “I’m not a bad person, sir. I do have a drug problem. I’ve been in front of you multiple times. I respect you. And I respect your decision that you make today.”
Lucci sentenced Bryant to 22 years in prison. That’s significantly more than the 12-year sentence that Bryant’s co-defendant received.
Bryant wasn’t happy about that—and he let Lucci know.
According to the transcript of the exchange included in the state Supreme Court’s ruling:
BRYANT: Fuck your courtroom, you racist ass bitch. Fuck your courtroom, man. You racist as fuck. You racist as fuck. Twenty-two fucking years. Racist ass bitch. (CONTINUED OUTBURST BY DEFENDANT, SWEARING, YELLING, MUCH UNINTELLIGIBLE).
COURT: Remember when—
BRYANT: You ain’t shit.
COURT: Remember when I said that you had some remorse?
BRYANT: You ain’t shit. You never gave me probation.
COURT: Wait a minute.
BRYANT: You never gave me a chance.
COURT: When I said that you had a certain amount of remorse, I was mistaken. (DEFENDANT CONTINUES YELLING). The Court determines—
BRYANT: Fuck you.
COURT: The Court determines that maximum imprisonment is needed, so it’s eleven years on Count 1 and eleven years on Count 3.
BRYANT: Fuck that courtroom. You racist bitch. You ain’t shit. (MALE VOICE SAYING “MANSON” REPEATEDLY). Let me out the courtroom, man. (MORE SHOUTING AND SWEARING).
COURT: So, it’s twenty-eight years with credit for two hundred and thirty-one days. Hold on. (DEFENDANT STILL SHOUTING). Does counsel waive your client’s presence for the remainder of the advisements I have to give?
DEFENSE COUNSEL: Yes, Your Honor.
COURT: Alright. You can take him. The Court determines that [Bryant] has shown no remorse whatsoever. I was giving him remorse, a certain amount of remorse in mitigation of the sentence. [Bryant] has shown me that he has no remorse whatsoever, and therefore the Court determines that maximum imprisonment is needed.
Lucci ultimately sentenced Bryant to 28 years behind bars, up from the 22 years he had originally indicated, linking the additional six years directly to his belief that Bryant was not, in fact, remorseful.
In 2020, an appellate court confirmed the sentence. Bryant, representing himself, appealed.
In a 4-3 ruling last week, the Ohio Supreme Court reversed the appellate court’s decision and modified the sentence.
At the heart of the majority’s ruling is the determination that while Ohio law allows a trial court to consider several factors in fashioning a sentence. Those include the extent of the victim’s injury, the defendant’s criminal history, and whether the defendant has shown remorse.
Disrespect for the court was not one of those factors.
“Bryant’s angry, profanity-laced tirade was, in no uncertain terms, disrespectful to the court,” the decision said. “Not only did Bryant accuse the trial-court judge of being a racist, but he did so using derogatory terms and in open court. As impertinent as this tirade was, however, we agree with Bryant that it is clear from the timing and content of what was said that his outburst was in reaction to the length of his prison sentence. Nothing more.”
The majority opinion said that Lucci’s stated reason for the extra years—that the additional six years were the result of a lack of remorse on Bryant’s part—was pretextual.
In sentencing, the Supreme Court ruled, a trial judge isn’t allowed to increase a sentence “merely because the defendant had an outburst or expressed himself in a profane and offensive way.”
The state Supreme Court said that the judge’s decision to tack on six more years appeared hasty, noting that just moments earlier, before Lucci issued his 22-year sentence, Bryant had, indeed, expressed remorse.
“The only significant differences between the two expressions are the words used and the way in which the words were conveyed,” the ruling said. “But what is perhaps most concerning about the trial court’s decision to increase Bryant’s sentence is that without a moment’s reflection, it added an additional six years onto a sentence that had already been imposed.”
The state supreme court said that the remedy for Bryant’s outburst was to hold him in contempt of court, but not necessarily to add a nearly 20 percent increase to the sentence.
“If a defendant’s outburst or other courtroom misbehavior causes a significant disruption that obstructs the administration of justice, that behavior may be punishable as contempt of court,” Justice Melody Stewart wrote for the majority. “The behavior, however, may not result in an increased sentence for the underlying crime.”
A three-judge dissent argued that Lucci, the trial judge, was allowed to consider Bryant’s outburst in determining his sentence, because it could be perceived as related to whether the defendant’s expression of remorse was sincere.
“The trial court is permitted to consider that in-court outburst in sentencing: here, the in-court outburst directly related to whether appellant, Manson Bryant, had displayed genuine remorse for committing various crimes or whether he was just pretending to have remorse with the hope of receiving a more lenient sentence,” wrote Justice Sharon Kennedy. “And under this court’s [precedent], neither this court nor the court of appeals has the authority to review Bryant’s increased sentence.”
The majority modified Bryant’s sentence back to the original 22 years and remanded the case back to Lucci’s court to issue a corrected sentencing entry.
Read the Ohio Supreme Court’s decision, below.
[Images via Ohio Department of Rehabilitation and Correction and YouTube screengrab/WJW.]
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