State v. Carpenter
2017 Ohio 8905
| Ohio Ct. App. | 2017Background
- Defendant Abram Carpenter was tried and convicted in Clark County, Ohio, after bench trial of two counts of first-degree rape (victim H.C., his sister), alleged to have occurred when he was ~15 and she was 3–5.
- H.C. testified to repeated sexual assaults at two family homes (Fairborn and Clark County), including digital and penile penetration and insertion of a screwdriver; abuse allegedly stopped after father intervened.
- Report made to law enforcement in October 2015; recorded reconciliation meeting (Dec. 2015) and recorded phone call (Jan. 2016) supplied to detectives; indictment filed April 2016 alleging offenses in 1998–1999.
- Carpenter waived jury trial; bench trial Aug 30–Sept 2, 2016; found guilty Sept 6, 2016; sentenced Oct 6, 2016 to concurrent 4-year terms and designated a sexually oriented offender.
- On appeal, Carpenter raised (1) constitutional challenge to statutory provisions requiring prosecution of certain juvenile offenders as adults, and (2) insufficiency/manifest-weight challenge to the rape convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Constitutionality of mandatory bindover/prosecution as adult under R.C. provisions | State: statutes valid under Ohio law and constitutional (due process/equal protection) | Carpenter: unconstitutional to try him as adult for offenses committed as a juvenile; violates due process/equal protection | Court: overruled; after Ohio Supreme Court’s Aalim II, mandatory bindover statutes are constitutional |
| 2. Sufficiency of evidence for rape convictions | State: H.C.’s testimony, if believed, satisfies elements of rape (penetration, victim <13) | Carpenter: evidence insufficient and verdict against manifest weight; allegations fabricated due to childhood dislike | Court: evidence legally sufficient; convictions not against manifest weight; trial court credited victim’s detailed testimony |
Key Cases Cited
- State v. Aalim, 83 N.E.3d 883 (Ohio 2017) (reconsideration holding mandatory juvenile bindover statutes constitutional)
- State v. Aalim, 83 N.E.3d 862 (Ohio 2016) (earlier decision invalidating mandatory bindover; later vacated on reconsideration)
- State v. Warren, 887 N.E.2d 1145 (Ohio 2008) (upheld prosecuting as adult where offenses committed as juvenile; due process not violated)
- State v. McKnight, 837 N.E.2d 315 (Ohio 2005) (distinguishes sufficiency vs. manifest-weight standards)
- State v. DeHass, 227 N.E.2d 212 (Ohio 1967) (factfinder credibility determinations entitled to deference)