State ex rel. Steffen v. Myers
39 N.E.3d 483
Ohio2015Background
- Steffen convicted in 1982 for aggravated murder, rape, and aggravated burglary; jury recommended death; conviction and sentence affirmed on direct appeal.
- DNA testing in 2006 excluded Steffen as the source of the semen found around the victim; the test undermined guilt-phase testimony.
- 1963-1982 trial record: new-trial motion based on newly discovered evidence; court reduced rape to attempted rape and ordered a new sentencing hearing under R.C. 2929.06(B).
- Dispute over remedy: whether 2929.06(B) applies when resentencing is ordered for newly discovered evidence rather than a sentencing error.
- Trial court agreed to hold a new capital-resentencing hearing; Steffen sought prohibition; First District dismissed, holding defendant can appeal after resentencing and that 2929.06(B) applies under White.
- Ohio Supreme Court affirms the appellate dismissal, holding Judge Myers was authorized by law to conduct a capital-resentencing hearing under 2929.06(B).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 2929.06(B) applies when resentencing is ordered for newly discovered DNA evidence, not a sentencing error | Steffen | Myers | Yes; 2929.06(B) authorized the resentencing hearing |
| Whether the state is bound by concessions about jurisdiction | Steffen | State | Concessions do not bind the court on legal issue of jurisdiction |
| Whether prohibition lies where there is an adequate ordinary remedy | Steffen | Myers | Prohibition proper where court lacked patent jurisdiction is not shown; here jurisdiction exists under 2929.06(B) |
| Whether error under 2929.06(B) includes reliance on now-excluded semen evidence | Steffen | Myers | Error includes reliance on evidence that former semen source was Steffen; supports resentencing hearing under White |
| Whether White governs eligibility for resentencing under 2929.06(B) | Steffen | State/Myers | White supports holding a capital resentencing hearing under 2929.06(B) |
Key Cases Cited
- State ex rel. Corn v. Russo, 90 Ohio St.3d 551 (2001) (writ of prohibition standard; extraordinary relief)
- State ex rel. Furnas v. Monnin, 120 Ohio St.3d 279 (2008) (patently and unambiguously lacks jurisdiction)
- State ex rel. Enyart v. O’Neill, 71 Ohio St.3d 655 (1995) (general jurisdiction/adequate remedy by appeal principle)
- State ex rel. Cleveland Elec. Illum. Co. v. Cuyahoga Cty., 88 Ohio St.3d 447 (2000) (example of patent lack of jurisdiction doctrine)
- State v. White, 132 Ohio St.3d 344 (2012) (interprets 2929.06(B) to include errors that occur in sentencing phase regardless of guilt verdict)