State v. Adl, 2022 Ohio 2692

On July 20, 2021, Qasim Adl was indicted on aggravated murder, murder, felonious assault, and having weapons while under disability; firearm specifications attached to Counts 1–3.
Early morning July 5, 2020, Terrance Nelson was shot multiple times next to his gray vehicle; 13 9mm casings at the scene were fired from the same firearm.
Eyewitness Ava Griffin (Adl's then-girlfriend) testified that after a gray car pulled up and Adl's "street mother" said "that's the peoples," Adl ran toward the vehicle and fired in the air; she later called 911 and told police Adl had fired.
Other neighbors heard multiple gunshots; victim sustained multiple gunshot wounds; police did not locate Adl on scene.
Defense presented no witnesses; jury convicted Adl of murder (lesser included), murder as charged, felonious assault (with firearm specifications), and having weapons while under disability; the court merged counts and sentenced Adl to life with parole eligibility after 21 years.
Adl appealed, raising sufficiency, manifest-weight, hearsay admission, and Batson/peremptory-challenge claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence	State: eyewitness and forensic evidence (consistent testimony; casings from one gun) suffice	Adl: lack of direct/forensic proof tying gun to him; Griffin not credible; she did not see him shoot victim	Court: Evidence sufficient; reasonable juror could find guilt beyond reasonable doubt
Manifest weight	State: testimony and physical evidence were consistent and credible	Adl: Griffin intoxicated, had poor eyesight, injured, and inconsistent to be trusted	Court: No miscarriage of justice; verdict not against manifest weight
Hearsay (street mother's statement)	State: statement not offered for truth but to explain Adl's reaction (effect on listener)	Adl: statement inadmissible hearsay and should have been excluded	Court: Admission proper as non-hearsay (to show effect); alternatively harmless error
Batson / peremptory challenges	State: prosecutor gave race-neutral reasons for excusals (criminal history, hearing issues, inability to jury-serve)	Adl: prosecutor struck African-American jurors based on race	Court: Trial court credited race-neutral explanations; no clear error; Batson claim denied

State v. Jenks, 61 Ohio St.3d 259 (sufficiency-of-evidence standard for criminal convictions)
State v. Wilks, 154 Ohio St.3d 359 (clarifying sufficiency/manifest-weight framework)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard; new-trial discretion)
State v. Osie, 140 Ohio St.3d 131 (extrajudicial statements admissible to show effect on listener)
State v. Thomas, 61 Ohio St.2d 223 (out-of-court statements explain witness actions)
Batson v. Kentucky, 476 U.S. 79 (peremptory challenges may not be used discriminatorily)
State v. Johnson, 144 Ohio St.3d 518 (Ohio application of Batson three-step inquiry)
State v. Thompson, 141 Ohio St.3d 254 (deference to trial court on Batson findings)
State v. Cepec, 149 Ohio St.3d 438 (Batson and discriminatory jury selection principles)
State v. Martin, 20 Ohio App.3d 172 (new-trial standard; exceptional-case language)