State v. Bridgeman
2011 Ohio 2680
Ohio Ct. App.2011Background
- Bridgeman was convicted after a jury trial in Champaign County Common Pleas Court of aggravated robbery, aggravated burglary, and grand theft ($5,000–$100,000) with firearm specs, arising from the December 17, 2007 Christiansburg bank robbery; aggregate sentence 13 years and $8,218 restitution.
- Evidence included DNA on a ski mask and glove matching Bridgeman; boots and clothing found near Alcony Conover Road; dye pack located near Bridgeman’s residence vicinity in Troy.
- Bank robbery occurred in Champaign County and was supported by multiple witnesses and a surveillance video showing a masked robber in dark clothing, with items later linked to Bridgeman.
- Bridgeman offered testimony claiming he was at home until around 1:00 p.m. and that missing items (ski mask, gloves) could have come from his girlfriend’s party, while police established more inculpatory links.
- The trial court admitted DNA evidence and other physical links; the State maintained Bridgeman was the robber; Bridgeman appealed challenging evidence, trial rulings, and sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence and venue | Bridgeman contends the State failed on venue and identity | State argues sufficient venue and identity proofs | Venue proven by totality; evidence supports identity; Crim.R. 29 denied but sufficient evidence found |
| Boots demonstration as evidence | Bridgeman requested to try boots to show size incongruity | State argued risk of contamination and lack of protection | No reversible error; denial found harmless |
| Convictions vs. weight of the evidence | Concludes evidence was weak and inconsistent | Argues weight favors acquittal due to conflicting descriptions and DNA considerations | Convictions not against the manifest weight of the evidence |
| Allied offenses and sentencing | Allied offenses should merge; multiple punishments improper | Convictions upheld; merging not addressed at sentencing | Allied offenses must be merged; remand for resentencing with proper merger election |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (1997-Ohio-52) (Sufficiency standard for criminal evidence)
- State v. Jenks, 61 Ohio St.3d 259 (1991) (Syllabus test for sufficiency viewing evidence in prosecution's favor)
- State v. Headley, 6 Ohio St.3d 475 (1983) (Venue proof may be shown by totality of facts; right to trial in proper county)
- State v. Draggo, 65 Ohio St.2d 88 (1981) (Venue and jurisdiction principles)
- State v. Gonzalez, 188 Ohio App.3d 121 (2010-Ohio-982) (Venue proof without direct testimony is permissible)
- State v. Johnson, 2010-Ohio-6314 (Ohio Supreme) (Allied offenses under 2941.25 methodology and merger guidance)
- State v. Whitfield, 124 Ohio St.3d 319 (2010-Ohio-2) (Remand when merger errors require election of allied offense)
- State v. Underwood, 2010-Ohio-1 (2010) (Statutory merger rules for allied offenses)
- State v. Coffey, 2007-Ohio-21 (2007) (Plain-error and allied offenses merger principles)
- State v. Puckett, Greene App. No. 97 CA 43 (1998) (Guidance on merger and sentencing)