State v. Baker, 2014 Ohio 3163

Baker was convicted by a jury in Montgomery County Court of Common Pleas on four counts of murder, two counts of aggravated robbery, and two counts of felonious assault, each with a firearm specification, with some counts merged on sentencing.
The offenses arose from a December 22, 2011 robbery and shooting at the Cash and Go pawn shop, involving Baker, Darren Taylor, and Anthony Dewayne McClain.
Golub, a pawn shop employee, and McClain died from gunshot wounds; Baker, Taylor, and McClain fled to Detroit after the incident.
Evidence linked Baker to the crime through surveillance video, a found gun, van ownership, cell phone data, a lottery ticket, and DNA analysis.
Baker challenged the verdict on weight and sufficiency of the evidence and raised a claim of ineffective assistance of counsel; the trial court’s judgment was appealed as to those issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence to sustain the murder and related counts?	Baker argues the State failed to prove elements beyond a reasonable doubt.	State contends evidence showed accomplice liability for robbery/murder.	Sufficiency supported; reasonable juror could find guilt beyond a reasonable doubt.
Was the verdict of murder and related offenses against the weight of the evidence?	Weight of the evidence favored Baker’s innocence or lesser culpability.	State asserts the jury reasonably weighed credibility and inferences.	No manifest miscarriage of justice; conviction not against the weight of the evidence.
Did Baker receive effective assistance of counsel?	Counsel lacked Franks-related knowledge, miscommunicated with jury, and frustrated the court.	Defense conduct during suppression, voir dire, and challenges for cause did not prejudice the defense.	Counsel provided effective assistance under Strickland v. Washington standard.

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for sufficiency of evidence; juries assess credibility)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency review uses viewing evidence in light most favorable to prosecution)
State v. Goff, 82 Ohio St.3d 123 (Ohio 1998) (credibility and weight of witness testimony are for the trier of fact)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (syllabus: appellate review standards; evidence sufficiency principle)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong ineffective assistance standard; reasonable objective assistance)
Bradley v. Ohio, 42 Ohio St.3d 136 (Ohio 1989) (adopts Strickland standard for ineffective assistance in Ohio)