State v. Boaston
100 N.E.3d 1002
| Ohio Ct. App. | 2017Background
- Victim Brandi Gonyer‑Boaston was found strangled in her car on Feb 15, 2014; appellant Ronald Boaston was indicted for aggravated murder and murder and later convicted of murder.
- Two weeks before her death Brandi reported an incident in which Boaston tried to drown her in the bathtub; multiple witnesses described bruising and Brandi’s statements about fear of Boaston.
- On Feb 14 Brandi visited Boaston’s apartment in the morning; he was the last known person to see her alive. Cell‑tower records, gaps in Boaston’s phone activity, scratches on Boaston, a tear in his coat, and Brandi’s hair on his glove were presented at trial.
- The coroner opined Brandi died within 1–2 hours after eating a breakfast sandwich; the coroner also performed a side‑by‑side comparison of a glove buckle with an abrasion under the victim’s chin.
- Pretrial: defense learned of certain coroner opinions ~19 days before trial but did not move to compel supplementation or exclude the testimony before jury empanelment; many objections were raised at trial and on appeal.
Issues
| Issue | State's Argument | Boaston’s Argument | Held |
|---|---|---|---|
| Admissibility of coroner’s time‑of‑death testimony under Crim.R.16(K) | Testimony was proper and probative; failure to exclude at trial forfeited objection | State failed to supplement autopsy report with written summary as required by Crim.R.16(K); testimony should be excluded | Waiver: defense failed to timely move under Crim.R.12; Crim.R.16(A) due diligence requirement meant pretrial motion was required, so objection waived |
| Admissibility of coroner’s glove‑buckle comparison (16(K) issue) | Comparison is factual/expert work offered at trial; same discovery waiver rule applies | Opinion from coroner about side‑by‑side comparison was not in written report as required by Crim.R.16(K) and should be excluded | Waiver for same reasons as time‑of‑death issue; objection not sustained |
| Cell‑tower location evidence / need for Daubert hearing | Cell‑tower testimony explains records; testimony need not be treated as specialized expert opinion | Reliability of tower‑based location evidence requires a Daubert analysis/hearing | No plain error: defense did not raise reliability objection at trial; courts have permitted lay testimony about tower utilization, so absence of a Daubert hearing was not an obvious error |
| Admission of prior acts / hearsay about the bathtub incident | Prior incident and victim statements show identity, intent, state of mind, and are admissible under exceptions | Statements were impermissible character/other‑acts and hearsay when not within an exception | Court allowed testimony of prior assault (probative of identity); allowed victim’s state‑of‑mind statements but excluded some co‑worker/mother hearsay as not qualifying under excited‑utterance or present‑state exceptions; remaining errors deemed harmless |
| Prosecutor’s closing arguments | Remarks were proper or not prejudicial; no timely objection | Prosecutor misstated facts and argued facts not in evidence on multiple occasions | No plain error: closing reviewed as whole and did not rise to plain error requiring reversal |
| Cumulative error / due process | Errors were minimal and harmless collectively | Multiple harmless errors cumulatively deprived fair trial | No reasonable probability verdict would differ; cumulative‑error claim rejected |
| Sufficiency (Crim.R.29) — whether evidence proved purposefully causing death | Evidence including coroner’s opinion, timing, cell records gaps, physical evidence, motive/supporting acts, and being last person with victim supports conviction | State lacked direct evidence placing Boaston at scene in Fulton County at relevant time; evidence was circumstantial and insufficient | Sufficient: viewed favorably to prosecution, a rational juror could find all elements beyond reasonable doubt |
Key Cases Cited
- Rigby v. Lake County, 58 Ohio St.3d 269 (broad trial‑court discretion on admissibility of evidence)
- Daubert v. Merrell Dow Pharm., 509 U.S. 579 (federal reliability gatekeeping standard for expert testimony)
- State v. Barnes, 94 Ohio St.3d 21 (plain‑error standard under Crim.R.52(B))
- State v. Howard, 56 Ohio St.2d 328 (criminal rules discourage gamesmanship; require timely objections)
- State v. Madrigal, 87 Ohio St.3d 378 (cumulative error doctrine)
- State v. Thompkins, 78 Ohio St.3d 380 (sufficiency standard review)
- State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency of the evidence)