State v. Belton (Slip Opinion), 149 Ohio St. 3d 165

Background

In August 2008 Anthony Belton robbed a convenience store and shot attendant Matthew Dugan in the back of the head; security video, statements, and recovery of a Hi-Point 9mm linked Belton to the crime.
Belton was charged with aggravated murder (capital specifications) and aggravated robbery; he waived a jury and entered a no-contest plea before a three-judge panel in April 2012.
The three-judge panel found him guilty, merged specifications, proceeded on the felony-murder specification, and after mitigation hearing sentenced Belton to death; additional consecutive terms were imposed for robbery and firearm specifications.
On direct appeal Belton raised 20 propositions, including constitutional attacks on Ohio’s death-penalty statutes and procedures, suppression of his confessions, evidentiary and prosecutorial-misconduct claims, and ineffective-assistance claims.
The Supreme Court of Ohio reviewed the plea-hearing record (including interrogation videos, coroner testimony, expert reports, and mitigation evidence) and affirmed convictions and the death sentence.

Issues

Issue	Belton’s Argument	State’s Argument	Held
Whether the 2011 amendment to R.C. 2929.11 effectively repealed the death penalty	The amended sentencing-purpose language (requiring "minimum sanctions" and avoiding unnecessary government expense) conflicts with death-penalty statutes and thus repeals or precludes death sentences	Statutes are reconcilable; cost and rehabilitation considerations do not render death unavailable; no implied repeal	Rejected — no implicit repeal; R.C. 2929.03/2929.04 remain operative and death remains available in some cases
Whether a capital defendant who waives a jury and pleads guilty/no-contest has a Sixth Amendment right to a jury at sentencing (Apprendi/Ring/Hurst challenges)	Belton: even after a plea, a jury must find mitigating facts and decide whether aggravating circumstances outweigh mitigation because sentencing findings can increase punishment	State: Ohio requires fact-finder to determine guilt and aggravators before sentencing; weighing is a moral judgment, not an element-triggering Apprendi/Ring protections; three-judge panel procedure is statutory and constitutional	Rejected — when defendant waives jury and a three-judge panel finds guilt/aggravators, Sixth Amendment does not entitle defendant to a jury for the subsequent weighing/sentencing step
Whether Belton’s confessions should have been suppressed as coerced	Belton: detectives’ statements implied threats/promises (leniency or life vs. death), overcoming free will	State: Belton received Miranda warnings, signed a waiver, interviews were not coercive, detectives made no operative promises, totality supports voluntariness	Rejected — waiver and interviews were voluntary under totality of circumstances; suppression denial proper
Whether death sentence was inappropriate/proportionate given mitigation	Belton: mitigation (difficult childhood, mental-health issues, youth, limited record, remorse, prison adaptability) outweighs aggravator and death is disproportionate	State: aggravator (murder during aggravated robbery; close-range execution of cooperating clerk) outweighs mitigation; case comparable to other death sentences	Affirmed — aggravating circumstance outweighs mitigating factors beyond reasonable doubt; death sentence proportionate and appropriate

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial warnings and waiver rules governing interrogation)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (facts increasing penalty must be submitted to a jury)
Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (Apprendi applied to capital aggravating factors)
Hurst v. Florida, 136 S. Ct. 616 (U.S. 2016) (invalidating scheme that allowed judge to make critical findings necessary for death sentence)
Baze v. Rees, 553 U.S. 35 (U.S. 2008) (standard for Eighth Amendment method-of-execution challenges)
State v. Ketterer, 111 Ohio St.3d 70 (Ohio 2006) (procedures for plea and capital sentencing before a three-judge panel)
State ex rel. Bates v. Court of Appeals for the Sixth Appellate Dist., 130 Ohio St.3d 326 (Ohio 2011) (discussing interplay of plea waivers and capital procedure)
State v. Scott, 127 Ohio St.3d 317 (Ohio 2010) (availability of forum for lethal-injection protocol challenges)
State v. Powell, 132 Ohio St.3d 233 (Ohio 2012) (standards on cumulative error and capital-review principles)