State v. Adams
2016 Ohio 7772
Ohio Ct. App.2016Background
- Jason M. Adams was tried for complicity to aggravated robbery after 77‑year‑old Sam Jones was robbed and beaten on Jan. 14, 2014; surveillance, phone records, witness testimony, toy‑gun purchases, and cell‑phone call patterns tied Adams to co‑defendants Scott Lewis and Ed Hampton.
- Lewis and Hampton pled guilty before trial; Lewis testified against Adams and described planning and execution.
- Adams (a military veteran with no prior felony record) testified he was unaware of the planned robbery and claimed he was also a victim.
- A jury convicted Adams of complicity to aggravated robbery; the trial court sentenced him to nine years’ imprisonment.
- On appeal Adams raised six assignments of error; the appellate court affirmed all rulings except it vacated the post‑release control portion of the sentence and remanded for resentencing/appropriate advisement.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Adams) | Held |
|---|---|---|---|
| Whether conviction was against the manifest weight of the evidence | State: evidence (victim testimony, photos, surveillance, phone logs, co‑defendant testimony) shows serious physical harm and complicity | Adams: injuries not shown to meet statutory "serious physical harm"; testimony conflicted; he was a victim | Court: affirmed conviction — evidence sufficient and jury credibility determinations supported; injuries met serious‑harm definitions |
| Whether nine‑year sentence was inconsistent with co‑defendants’ lesser terms | State: court properly exercised sentencing discretion; differences in roles and lack of remorse justify variance | Adams: his sentence is greater than co‑defendants who did the physical violence, so inconsistent and unsupported | Court: overrule — defendant failed to preserve proportionality evidence at sentencing; nine years within statutory range and not contrary to law |
| Whether it was plain error to inform jury that co‑defendants pled guilty | State: telling the jury was proper to explain witness status and anticipated defense attacks; plea used for impeachment/credibility | Adams: multiple references to pleas unfairly prejudiced him and should have been excluded or limited | Court: overrule — no plain error; plea references served proper impeachment purpose, were not unduly emphasized, and defense strategy invited/use mitigated impact |
| Whether failure to advise of post‑release control rendered sentence (in part) void | State: post‑release control must be imposed and properly advised at hearing and entry | Adams: he was not advised at sentencing hearing of mandatory post‑release control or sanctions | Held: sustain — sentencing entry alone was insufficient; court vacated/voided that portion and remanded for resentencing consistent with R.C. 2929.191 and controlling Ohio law |
| Whether trial counsel was ineffective for not objecting to plea references | State: counsel’s choice was reasonable trial strategy; overwhelming circumstantial evidence of guilt negates prejudice | Adams: failing to object to repeated plea references deprived him of fair trial | Court: overrule — counsel’s inaction was tactical and not shown to be prejudicial under Strickland |
Key Cases Cited
- Thompkins v. Ohio, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight standard)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective‑assistance standard)
- State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (post‑release control advisement requirement)
- State v. Jordan, 104 Ohio St.3d 21 (Ohio 2004) (post‑release control notice at sentencing and entry)
- State v. Eley, 56 Ohio St.2d 169 (Ohio 1978) (evidentiary sufficiency for conviction)