State v. Brooks
2017 Ohio 2832
| Ohio Ct. App. | 2017Background
- Maurice E. LaPaul Brooks was convicted in 1993 of three counts of aggravated murder with firearm and death specifications; convictions were affirmed and death sentences later vacated by the Ohio Supreme Court, leading to resentencing to three consecutive life terms with parole eligibility after 90 years.
- Brooks previously filed multiple post-conviction/void-judgment petitions challenging that he was indicted under the name "Antonio M. Brooks" rather than his true name; earlier petitions were denied and affirmed on appeal.
- In August 2016 Brooks filed another petition for post-conviction relief asserting lack of subject-matter jurisdiction due to misnomer in the indictment and ineffective assistance for not challenging the indictment name.
- The trial court denied the 2016 petition as untimely and successive under R.C. 2953.23(A); the appellate court reviewed the denial de novo because it turned on legal timeliness requirements.
- The court held Brooks failed to satisfy the narrow exceptions permitting untimely or successive post-conviction petitions and therefore the trial court lacked authority to consider the petition on the merits.
Issues
| Issue | Plaintiff's Argument (Brooks) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the trial court lacked subject-matter jurisdiction because indictment named "Antonio M. Brooks" rather than Brooks's true name | Indictment misnamed him; conviction void for lack of jurisdiction | Challenge is an untimely/successive collateral attack subject to R.C. 2953.23; not a jurisdictional voidness exception | Denied — court lacked authority to hear because Brooks did not meet R.C. 2953.23 exceptions |
| Whether trial/appellate counsel were ineffective for failing to challenge the indictment name | Counsel violated Sixth Amendment and Ohio Constitution by not attacking indictment identity/sufficiency | Ineffective-assistance claim is procedurally barred as untimely/successive and thus not properly before the court | Denied — claim barred by procedural requirements; court did not reach merits |
Key Cases Cited
- State v. Brooks, 75 Ohio St.3d 148 (Ohio 1996) (Ohio Supreme Court vacated death sentences and remanded for resentencing)
- State v. Brooks, 118 Ohio App.3d 444 (9th Dist. 1997) (appellate decision affirming the trial court's resentencing to life terms)