State v. Adams (Slip Opinion), 144 Ohio St. 3d 429

Adams was convicted by a Mahoning County jury of aggravated murder in 1985 related to the rape and murder of Gina Tenney and was sentenced to death; the Seventh District affirmed, and this court reviews post-conviction issues.
Trial evidence included DNA testing in 2007–2008 linking Adams to the semen on Tenney and to Tenney’s underwear, while Landers and Passarello were excluded as sources; a voicemail-like card and various items tied Adams to Tenney’s apartment.
Key physical items included a ring of keys, a potholder with hair, an unplugged TV, and Tenney’s ATM card found in Adams’s jacket; fingerprints on the TV matched Adams.
Lineups and identifications involved John and Sandra Allie, with Sandra admitting a prior misidentification; the court addresses Batson and eyewitness identification challenges.
After decades, the court remands for resentencing because the capital specification under R.C. 2929.04(A)(7) was not proven with respect to aggravated burglary, though the underlying aggravated-murder conviction remains valid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the capital specification is proven with respect to multiple predicate offenses	Adams argues the omnibus specification failed to prove all alternative means	State contends each alternative means need not be proven unanimously	Death sentence vacated; remanded for resentencing; aggravated-murder conviction affirmed
Constitutional speedy-trial and preindictment delay claims	Speedy-trial rights violated by prosecution in 2007 for a 1985 crime; preindictment delay prejudicial	Delay not presumptively prejudicial; Meeker/Doggett analysis applied; delay not due to tactical advantage	Statutory speedy-trial rights not violated; constitutional speedy-trial rights not violated; preindictment delay not shown to cause prejudice
Voir dire time limits and panel conduct	Time limits and questioning method denied meaningful voir dire	Trial court has broad discretion; no abuse of discretion shown	No plain error or abuse of discretion; proceedings upheld
Admission of Tenney-related hearsay and state-of-mind evidence; Miranda and suppression issues	Evidence of fear and excited utterances improperly admitted; Miranda waiver questioned	Waivers voluntary; no coercion; statements admissible	No reversible error; evidence admitted; Miranda issues resolved against Adams

Griffin v. United States, 502 U.S. 46 (U.S. Supreme Court, 1991) (unanimity not required for alternate means when verdict is general)
Schad v. Arizona, 501 U.S. 624 (U.S. Supreme Court, 1991) (allows multiple theories of guilt; jury need not be unanimous on a single theory)
Sochor v. Florida, 504 U.S. 527 (U.S. Supreme Court, 1992) (upheld death sentence despite unproven aggravating factor when remaining basis supports sentence)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. Supreme Court, 2000) (required jury finding for any fact increasing maximum punishment)
Alleyne v. United States, 570 U.S. 99 (U.S. Supreme Court, 2013) (mandatory facts increasing minimums must be found by the jury)
State v. Johnson, 112 Ohio St.3d 210 (Ohio Supreme Court, 2006) (unanimity not required on which predicate offense justified aggravated murder)
State v. Gardner, 118 Ohio St.3d 420 (Ohio Supreme Court, 2008) (alternative-means rule for capital specification)
State v. Davis, 116 Ohio St.3d 404 (Ohio Supreme Court, 2008) (capital-sentence review under R.C. 2929.05(A))