State v. Adams
2012 Ohio 4382
Ohio Ct. App.2012Background
- Adams and Isaac were involved in an armed robbery that resulted in Isaac’s death.
- Adams was convicted at trial on murder, aggravated robbery, burglary, tampering with evidence, and having weapons while under disability.
- The tampering conviction under R.C. 2921.12(A)(1) involved Adams allegedly removing the gun from the crime scene to impair its evidentiary value.
- Evidence included testimony that Adams moved the gun, discarded marijuana, and that DNA linked Adams to the gun and that a witness saw him with the gun after the robbery.
- Jarvis and Becker housed Adams after the incident; Adams’ gun later was located, and gun was linked to the deceased victim during trial.
- The appellate court affirmed, holding the tampering conviction supported by sufficient evidence and not against the manifest weight of the evidence, with standard to review sufficiency and weight explained.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Tampering conviction is supported by sufficient evidence? | Adams argues insufficient evidence. | State argues sufficient, circumstantial evidence links Adams to gun. | Tampering conviction supported; evidence sufficient. |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for evaluating sufficiency of evidence)
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (weight-of-evidence framework; 'thirteenth juror' concept)
- State v. Otten, 33 Ohio App.3d 339 (Test. Dist. 3rd) (weight and credibility assessment on appeal)
- State v. Tucker, 2006-Ohio-6914 (9th Dist.) (illustrates appellate review of weight/sufficiency)