State v. Canales, 2017 Ohio 5552

Defendant Cesar Canales lived with the victims and was convicted after a jury trial in Stark County for two counts of rape and two counts of gross sexual imposition involving the victims, sisters C.M. (age 12 at disclosure) and A.P. (age 8 at disclosure).
The girls disclosed abuse to a friend, which led to reporting; medical exams and forensic interviews at Akron Children’s Hospital occurred the same day.
C.M. testified that Canales repeatedly engaged in vaginal intercourse with her, including the night before disclosure; A.P. testified Canales repeatedly touched her vagina and attempted intercourse but could not complete it.
Y-STR male-specific DNA testing detected male DNA on C.M.’s vaginal swab and underwear; the profiles were consistent with Canales and had rarity estimates of 1 in 5,556 and 1 in 6,250 unrelated males, respectively.
The jury found Canales guilty on all counts; the trial court imposed an aggregate sentence of life with parole eligibility after 15 years and designated him a Tier III sex offender.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for rape and GSI convictions	State: testimony from both victims plus DNA evidence established elements beyond a reasonable doubt	Canales: convictions unsupported by sufficient credible evidence and against manifest weight	Court: Evidence (victim testimony + DNA) was sufficient; convictions affirmed
Manifest weight of the evidence	State: inconsistencies did not undermine core testimony; jury entitled to assess credibility	Canales: jury lost its way given alleged inconsistencies and weaknesses in proof	Court: No miscarriage of justice; jury was best judge of credibility; verdict not against manifest weight

C.E. Morris Co. v. Foley Constr., 54 Ohio St.2d 279, 376 N.E.2d 578 (Ohio 1978) (establishes standard for reviewing whether judgment is against manifest weight)
Eastley v. Volkman, 132 Ohio St.3d 328, 972 N.E.2d 517 (Ohio 2012) (every reasonable presumption must favor the trial court when reviewing weight of the evidence)
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77, 461 N.E.2d 1273 (Ohio 1984) (appellate review presumption in favor of trial court findings)
State v. DeHass, 10 Ohio St.2d 230, 227 N.E.2d 212 (Ohio 1967) (trial court is best positioned to determine witness credibility)
Glasser v. United States, 315 U.S. 60 (U.S. 1942) (deference to factfinder credibility assessments)
Marshall v. Lonberger, 459 U.S. 422 (U.S. 1983) (appellate courts should not reweigh evidence of credibility)
State v. Antill, 176 Ohio St. 61, 197 N.E.2d 548 (Ohio 1964) (jury may accept portions of witness testimony and reject others)