Sandusky County Judge Removed from Office for Multiple Judicial Conduct Violations

The Supreme Court of Ohio today suspended Sandusky County Common Pleas Court Judge Jon Ickes for two years due to several judicial conduct violations, including presiding over two cases in which he had a “glaring conflict of interest” and cultivating an unprofessional workplace environment.
Ickes was appointed to the court’s general and domestic relations division in 2020 and elected to a full six-year term beginning in January 2021. Today, the Supreme Court immediately removed him from judicial office without pay for the duration of his suspension.
Writing for the Court majority, Chief Justice Sharon L. Kennedy stated that the purpose of judicial discipline is to protect the public, guarantee the evenhanded administration of justice, and maintain and enhance public confidence in the integrity of the judiciary. Ickes’s refusal to disqualify himself when his impartiality might have reasonably been questioned “caused incalculable harm to the public confidence in the independence, integrity, and impartiality of the judiciary,” she wrote.
The Board of Professional Conduct, which found that Ickes committed 10 of the 17 charged judicial rule violations, recommended that the Court suspend the judge for one year, with the suspension fully stayed on the condition that he not commit further misconduct. The Court determined that a more severe sanction was necessary.
Justices Patrick F. Fischer, Daniel R. Hawkins, and Megan E. Shanahan joined Chief Justice Kennedy’s opinion. Fourth District Court of Appeals Judge Michael D. Hess, sitting for Justice Jennifer Brunner, also joined the majority opinion.
Justice R. Patrick DeWine stated he would impose a one-year suspension, with six months stayed. Justice Joseph T. Deters stated he would impose a two-year suspension, fully stayed, with the conditions that Ickes not commit further misconduct and complete a course on anti-harassment training.
Failure to Recuse, Workplace Antics Lead to Multiple Complaints
In January 2025, the Office of the Disciplinary Counsel filed a complaint with the board against Ickes, alleging that he committed 17 violations of the Code of Judicial Conduct. The office maintained that the judge had harassed a pregnant employee, fostered an unprofessional work environment, used a racial slur within earshot of a criminal defendant, used a lewd and vulgar nickname for a child rape case, and failed to disqualify himself in two cases where his stepson testified as the state’s law enforcement witness.
In December 2022, Curtis Elkins was charged with five felonies for firing a gun several times into another vehicle, which the Court referred to as the “drive-by case.” Elkins had also been indicted in an unrelated assault case in September 2022.
In the drive-by case, Elkins was arrested by Fremont Police Department Officer Christian Ortolani, Ickes’s stepson. Ickes presided over the pretrial hearings in both cases and the assault case’s trial. In violation of the judicial rules, he never disclosed his relationship to Ortolani on the record nor sought a waiver of disqualification from the parties, which would have allowed him to preside over the cases.
During the assault case, Ortolani testified about investigating crimes in the Fremont area and interviewing Elkins. A jury found Elkins guilty, and at his sentencing hearing, the prosecution referred to Elkins’s interview with Ortolani. Ickes sentenced Elkins to a term of six to nine years in prison.
In the drive-by case, Elkins requested Ickes recuse himself, given his relationship to Ortolani, who Elkins described as the investigation’s “lead detective.” Ickes ultimately recused himself from the drive-by case, which was subsequently dismissed after the eyewitness left the state.
Elkins appealed his sentence in the assault case to the Sixth District Court of Appeals, which reversed his conviction. The appellate court found an “unconstitutional potential for bias” since there was no evidence indicating that Elkins or his attorney knew Ortolani was Ickes’s stepson. It also noted that Ickes recused himself in the drive-by case when Elkins raised the conflict.
Inappropriate Bench Behavior Occurs in Second Case Involving Stepson
The board found that Ickes committed several rule violations in a second case where he did not disclose his relationship to Ortolani, the arresting officer.
In 2023, Leroy Stratton was indicted for rape after he livestreamed himself performing an oral sex act on an 18-month-old child. During the eight months the case was on Ickes’s docket, the judge regularly referred to it by using a lewd and vulgar term that one staff member called “disgusting,” and another said was disturbing.
During the February 2024 trial, Ickes participated in a text conversation from the bench with two of his staff members and the court administrator. Some of the texts mocked a potential juror, and during the trial, Ickes texted videos and comments to the staff that made light of the matter.
The board found that Ickes failed to promote public confidence in the independence, integrity, and impartiality of the judiciary, and did not require court staff, court officials, and others subject to the judge’s direction and control to act in a manner consistent with the judge’s obligations.
At the hearing, Stratton requested that Ickes recuse himself because Ortolani was the arresting officer and was involved in the investigation. He also noted that the judge never disclosed the relationship. Ickes refused, saying that Ortolani’s role in the case did not warrant his recusal.
Stratton was convicted and sentenced to life without the possibility of parole. He appealed his conviction, citing, among other things, the judge’s failure to recuse himself. As his appeal was pending, the Sixth District decided Elkins’s case. Based on that decision, the appellate court found that the possibility of bias violated Stratton’s due-process rights. It therefore vacated Stratton’s conviction and remanded the case for further proceedings.
Supreme Court Considered Sanction
When considering Ickes’s sanction, the Court opined that his failure to disclose the relationship to Ortolani “wasted prosecutorial, public-defender, and judicial resources” and caused incalculable harm to public confidence in the judiciary.
In recommending a fully stayed suspension, the board pointed to disciplinary cases where attorneys and judicial officers committed some similar misconduct. However, the Court noted that judges are held to a higher standard than other attorneys and that Ickes has not resigned despite the board’s findings. Consequently, it would be hard to justify a fully stayed suspension if the higher standards expected of judges were not enough to deter his misconduct.
Therefore, “an actual suspension is necessary to protect the public and demonstrate that we will not tolerate the childish, inappropriate, and vulgar behavior Ickes exhibited in chambers and in the courtroom,” the Court said.
The Court also required Ickes to pay the cost of the disciplinary proceedings.2025-1323. Disciplinary Counsel v. Ickes, Slip Opinion No. 2026-Ohio-3173.
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