State v. Anderson, 2017 Ohio 931

Defendant Shyne Anderson was tried to the bench on four consolidated indictments for multiple violent offenses against two intimate partners occurring July 2014–Dec. 2015; he pleaded not guilty and did not call witnesses.
The state moved to join the four cases; defense objected and the trial court overruled the objection and tried the cases together.
Victims Shana Saunders and A.W. testified in detail about separate episodes of assault, burglary/entry, kidnapping, sexual assault (some counts later dismissed), theft, and threats; police officers corroborated investigations and jail-call evidence.
The trial court convicted Anderson on multiple counts across the four cases, imposed concurrent terms within each victim’s cases but ordered the sentences for the two victims to run consecutively, yielding an aggregate 22-year sentence.
On appeal Anderson raised (1) manifest-weight challenge to convictions, (2) that joint trial admitted prejudicial “other acts” evidence in violation of Evid.R. 404(B) / R.C. 2945.59, and (3) ineffective assistance for failing to secure severance.
The appellate court affirmed, finding the weight/credibility determinations were for the factfinder and that joinder was proper under Crim.R. 8(A)/13 and the Crim.R. 14 joinder test ("simple and direct" evidence), making the Evid.R. 404(B) issue and ineffective-assistance claim meritless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Manifest weight of the evidence	State: victims’ testimony and police evidence supported convictions	Anderson: testimony was inconsistent or implausible (e.g., 20-foot window, self-inflicted injuries, equivocal sexual-penetration testimony)	Affirmed — appellate court defers to factfinder credibility; no miscarriage of justice
2. Admissibility / prejudice from joint trial (other-acts)	State: crimes were similar, part of a common scheme; evidence was simple and direct across incidents	Anderson: joinder allowed prejudicial other-acts evidence in violation of Evid.R. 404(B) and R.C. 2945.59	Affirmed — joinder permissible under Crim.R. 8(A)/13; evidence was simple and direct, so no undue prejudice
3. Ineffective assistance for failing to obtain severance	State: no prejudice from joint trial; counsel exercised reasonable strategy	Anderson: counsel should have preserved/obtained severance and challenged joinder successfully	Affirmed — no deficient result shown because joinder was proper and defendant not prejudiced
4. Sentencing/journal entry technicality	State: sentencing was proper and fines were imposed on each count	Anderson: suggested possible journal-entry issue about fines/sentencing	Court: noted journal entry imposed $250 fine "on each count," so Baker issue not implicated; judgment final and affirmed

State v. Thompkins, 78 Ohio St.3d 380 (discusses manifest-weight vs. sufficiency review)
State v. DeHass, 10 Ohio St.2d 230 (credibility determinations are for the trier of fact)
State v. Diar, 120 Ohio St.3d 460 (joinder favored when Crim.R. 8(A) satisfied)
State v. Lott, 51 Ohio St.3d 160 (‘‘simple and direct’’ joinder test; no prejudice when evidence of each crime is distinct)
State v. Franklin, 62 Ohio St.3d 118 (explains joinder vs. other-acts admissibility)
State v. Schiebel, 55 Ohio St.3d 71 (policy favoring joinder and avoiding multiple trials)
State v. Schaim, 65 Ohio St.3d 51 (joinder/severance principles)
State v. Torres, 66 Ohio St.2d 340 (joinder favored to conserve resources and avoid inconsistent results)
State v. Brinkley, 105 Ohio St.3d 231 (defendant bears burden to prove prejudice from joinder)
State v. Baker, 119 Ohio St.3d 197 (limits on aggregate sentencing entries; discussed re: journal entries)