State v. Anglin
2019 Ohio 588
Ohio Ct. App.2019Background
- At Brick Street Bar, G.M. and her friend K.W. drank alcoholic beverages; G.M. later appeared highly intoxicated. After the bar closed, K.W. escorted G.M. to her apartment and put her to bed because G.M. was "pretty incapacitated."
- Anglin (appellant), a karaoke participant who met G.M. that night, accompanied them briefly and later returned to G.M.'s apartment; K.W. found Anglin inside G.M.'s bedroom partially clothed and convinced him to leave.
- G.M. had limited memory of the night, felt disoriented and sick, called police, and underwent a sexual assault exam within hours.
- Forensic testing identified semen on a vaginal swab and matched Anglin's DNA to the swab (one-in-200-million statistical estimate); G.M.'s blood-alcohol content at 8:39 a.m. was 0.107, implying a higher BAC earlier.
- Anglin admitted in a recorded statement that he entered G.M.'s apartment through a window, engaged in oral sex, observed G.M. as drunk, and took steps to "double check" her awareness; he denied penetration and claimed he acted only with apparent invitation.
- Indicted for rape and sexual battery (merged for sentencing), Anglin was convicted of rape and sentenced to a mandatory four-year term; he appealed arguing insufficiency and that the verdict was against the manifest weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency: whether evidence proves rape under R.C. 2907.02(A)(1)(c) (substantial impairment of ability to consent and offender's knowledge) | State: testimony, BAC results, K.W.'s observations, DNA match, and Anglin's admissions support a finding G.M. was substantially impaired and Anglin knew or had reasonable cause to know | Anglin: insufficient proof that G.M. was substantially impaired or that he knew or should have known of impairment | Court: Evidence sufficient; reasonable jury could find beyond a reasonable doubt that G.M. was substantially impaired and Anglin knew or had reason to know |
| Manifest weight: whether conviction was against the weight of the evidence | State: credibility of witnesses and physical/DNA evidence weigh in favor of conviction | Anglin: jury should have credited defense account and acquitted | Court: Not against manifest weight; jury did not lose its way given the corroborating testimony, toxicology, and Anglin's own statements |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (sets the standard for sufficiency review: whether, viewing evidence in the light most favorable to the prosecution, any rational trier of fact could find essential elements proven beyond a reasonable doubt)
- State v. Zeh, 31 Ohio St.3d 99 (defines "substantial impairment" as present reduction in ability to appraise or control conduct)
- State v. Blankenburg, 197 Ohio App.3d 201 (2012) (12th Dist.) (appellate deference to jury credibility determinations; extraordinary circumstances required to reverse on manifest weight)