State v. Brown, 2017 Ohio 4231

Brown was convicted in Preble County Court of Common Pleas of rape, sexual battery, gross sexual imposition, and importuning based on allegations by the victim (B.H.) of sexual abuse years earlier.
The abuse allegedly occurred at a farm owned by a family friend while Brown and B.H. were there for farm work; portions were documented in B.H.’s journal.
Brown waived jury trial and was tried to a judge; the court found him guilty on all charges, with some counts merged into the rape conviction.
The court sentenced Brown to a term of ten years to life in prison after merging counts into the rape charge.
Brown appealed, raising multiple assignments of error related to trial conduct and defense representation.
At issue was whether the trial court properly denied motions for a new trial and whether Brown received effective assistance of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying a new-trial motion	Brown contends a Brady violation and surprise warranted a new trial	State argues no Brady violation and no prejudice from discovery concerns	Denied; no abuse of discretion; no material prejudice shown
Whether Brown received ineffective assistance of counsel	Brown asserts counsel failed to impeach or investigate the victim’s credibility	Counsel adequately cross-examined and pursued credibility; no prejudice shown	Denied; no deficient performance or prejudice shown

State v. Ruhlman, 2006-Ohio-2137 (Ohio 2006) (abuse of discretion standard for new-trial decisions; continuance as remedy when discovery issues arise)
State v. Hanna, 2002-Ohio-2221 (Ohio 2002) (Brady claim requires suppression after trial; evidence disclosed during trial is not Brady)
State v. Payne, 2010-Ohio-1018 (Ohio 2010) (no Brady violation where evidence disclosed during trial; discovery timing matters)
State v. Clarke, 2016-Ohio-7187 (Ohio 2016) (ineffective-assistance framework; Strickland standard applied)