State v. Campbell
2024 Ohio 3340
| Ohio Ct. App. | 2024Background
- Langston Campbell was arrested in Wood County, Ohio, after a traffic stop where officers discovered his passenger, M.B., with severe facial injuries; M.B. and her infant son had been reported missing in California the previous month.
- Investigation revealed M.B. had allegedly been held captive by Campbell since December 2023, subjected to physical abuse, deprived of access to her child, and had personal items (phone, identification) withheld.
- Campbell was indicted on multiple felonies including two counts of first-degree kidnapping, tampering with evidence, disrupting public services, and possession of criminal tools.
- The State moved to deny bail under R.C. 2937.222(A), asserting the seriousness of the offenses and risk posed by Campbell; the trial court granted the motion after a hearing.
- Campbell appealed, arguing the trial court failed to properly consider all statutory factors before denying bail.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether clear and convincing evidence supports bail denial under R.C. 2937.222 | State argued evidence showed Campbell committed the offenses, posed a substantial risk, and no condition could assure safety. | Campbell claimed evidence was insufficient, victim did not testify, and prior criminal history should not factor. | Affirmed: Sufficient evidence supported all three bail denial prongs. |
| Whether Campbell poses a substantial risk of harm to the victim/community | State cited violent felony charges, evidence of repeated violence, and lack of community ties. | Campbell argued he posed no ongoing threat as victim was not nearby. | Affirmed: Record supported substantial risk of serious harm. |
| Whether any release conditions could assure safety | State highlighted Campbell’s history, witness intimidation attempts, and jailhouse contacts. | Campbell asserted conditions could protect victim and community. | Affirmed: No conditions reasonably assured safety given conduct and history. |
| Appropriateness of considering criminal history/characteristics in bail analysis | State emphasized prior violence, active protection orders, and probation status. | Campbell contended court erred by weighing his prior criminal history. | Affirmed: Criminal history is a proper statutory factor in bail determination. |
Key Cases Cited
- Cross v. Ledford, 161 Ohio St. 469 (1954) (defining clear and convincing evidence standard)
- State v. Marcum, 2016-Ohio-1002 (Ohio 2016) (clear and convincing evidence standard in criminal context)
- State v. Blackshear, 2022-Ohio-230 (Ohio Ct. App. 2022) (standard for appellate review of bail denial)
- State v. Brown, 2006-Ohio-3377 (Ohio Ct. App. 2006) (firm belief or conviction suffices for clear and convincing evidence review)