State v. Almedom, 2016 Ohio 1553

Defendant Sefe A. Almedom was convicted in Franklin County on multiple counts of rape and gross sexual imposition based on allegations by three girls under age 13.
At trial the court and prosecutor repeatedly referred to the children as "victims" before testimony, including during voir dire and preliminary remarks.
The youngest alleged victim (age six at trial) was not called and the charge related to her was dismissed during the State's case.
Defense counsel made few pretrial motions, filed only a bill of particulars, did not move to determine competency of the child witnesses, and failed to object repeatedly to prosecutorial and judicial remarks and to admission of extrajudicial interviews.
On appeal the court reviewed assignments alleging denial of a new trial, due process/fair trial violations, ineffective assistance of counsel, and insufficiency/manifest-weight challenges.
The appellate court concluded defense counsel's performance and the trial judge's prejudicial comments deprived Almedom of a fair trial, vacated the convictions, and remanded for a new trial; sufficiency and manifest-weight claims were rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a new trial was required	No; trial errors were not so prejudicial as to require new trial	Trial was unfair due to judge/prosecutor comments and counsel's failures	Moot after court ordered new trial on other grounds
Whether due process / fair trial was denied by judicial/prosecutorial comments	Comments were harmless and did not determine verdict	Repeated references by judge/prosecutor to the children as "victims" tainted jury and denied impartial adjudication	Yes — court found comments, combined with counsel's failures, denied fair trial; assignment sustained
Whether counsel provided ineffective assistance	Prosecution: counsel's performance did not change outcome; evidence was sufficient	Counsel repeatedly failed to object, made no key pretrial motions, undermining adversarial process	Yes — performance objectively deficient and prejudicial to fairness; assignment sustained
Whether convictions were supported by sufficient evidence / against manifest weight	Evidence (children's explicit testimony and mother's observations) was sufficient; verdicts supported	Defendant argued insufficiency/credibility issues	No — court found evidence sufficient and not against manifest weight; assignment overruled

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part ineffective-assistance standard: deficiency and prejudice)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency inquiry: whether any rational trier of fact could find guilt beyond reasonable doubt)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (adopting Jackson standard for Ohio sufficiency review)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishing sufficiency and manifest-weight standards)
State v. Keith, 79 Ohio St.3d 514 (Ohio 1997) (discussing standards for evaluating ineffective-assistance claims)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (jury's role in assessing inconsistencies and witness credibility)