One hundred twenty-five years ago, the Supreme Court of Ohio upheld a decision involving the alleged embezzlement of 11 sheep. The case, Mitchell v. State, is currently featured in the Supreme Court’s display case in the Grand Concourse of the Thomas J. Moyer Ohio Judicial Center.

The America 250-Ohio Commission chose “Food and Farm Laws in Ohio” as its October theme. In recognition of this theme, the Court is highlighting Mitchell, a case that illustrates how financial crimes could affect Ohio's agricultural communities at the turn of the 20th century.

At the time, the U.S. Supreme Court defined "embezzlement" as “the fraudulent appropriation of property by a person to whom such property has been entrusted, or into whose hands it has lawfully come.”

Near the turn of the century, John W. Mitchell worked for Muskingum County farmer Leonard Guist. In 1899, Mitchell sold 11 sheep owned by Guist without authorization. A Muskingum County grand jury valued the sheep at approximately $30 each and indicted Mitchell on charges of embezzlement.

Mitchell argued that evidence in the case hadn’t appropriately proven intent for embezzlement, but the Muskingum County Common Pleas Court dismissed his argument and found him guilty. Mitchell appealed to the circuit court, which upheld the conviction, finding “no error in the record.” He appealed to the Supreme Court of Ohio.

On Oct. 8, 1901, the Supreme Court unanimously affirmed the circuit court’s decision in a per curiam opinion.

Embezzlement Laws in Ohio
The circuit court decision upheld by the Court has been cited seven times in subsequent Ohio cases addressing issues such as illegal possession and the fraudulent conversion of property.

Adjusted for inflation, the value of the 11 sheep, estimated at about $30 each in 1899, would total roughly $1,100 today.  However, the current value of sheep varies based on factors such as age, sex, and intended use. According to the U.S. Department of Agriculture, sheep currently sell for about $300 each, placing the value of 11 sheep at more than $3,000 today.

See Display in Person
Original court filings from Mitchell, including documents from the trial and appeals court, are part of the display. Plan a visit to the Court to view the America 250 display in the Grand Concourse.

America commemorated its 250th birthday on July 4, 2026, marking a historic milestone in the nation's journey. To honor the semiquincentennial, the Court hosted a year-long celebration titled “The Story of America,” highlighting significant historical events that shaped both the nation and Ohio. In addition to digital content, the initiative has featured special events and exhibits at the Court. The celebration aims to spark curiosity, strengthen civic literacy, and recognize pivotal moments in American and Ohio history.