State v. Casey, 2017 Ohio 790

Larry L. Casey was indicted on multiple sex-offense charges (sexual battery, rape, unlawful sexual conduct with a minor) and a separate indictment for failing to notify a change of address as a Tier III sex offender.
Allegations arose from conduct with victim N.J. between 2009 and 2014; some incidents were alleged to have occurred before N.J. turned 13.
Case proceeded to a four-day jury trial; N.J., then 15, testified to repeated sexual conduct with Casey; Casey denied the allegations and claimed a conspiracy.
The jury convicted Casey of two counts of sexual battery, one count of rape, unlawful sexual conduct with a minor, and the address-notification offense.
The trial court classified Casey as a sexually violent predator and imposed an indefinite sentence of 25 years to life.
On appeal Casey raised (1) ineffective assistance of trial counsel (failure to object to hearsay, unqualified expert testimony, and eliciting incarceration status), and (2) cumulative harmless errors depriving him of a fair trial. The Twelfth District affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Casey received ineffective assistance of counsel	Prosecution (State) contends trial counsel acted reasonably and strategic choices are entitled to deference	Casey argued counsel failed to object to numerous hearsay statements, failed to object to unqualified expert testimony, and elicited testimony about his incarceration without curative instruction, resulting in prejudice	Court held counsel's performance was within reasonable professional judgment; many statements were non-hearsay or admissible exceptions, expert testimony would have been proper, strategic choices and lack of prejudice defeat Strickland claim
Whether cumulative harmless errors deprived Casey of a fair trial	State argued no reversible errors occurred and thus cumulative-error doctrine inapplicable	Casey argued multiple harmless errors combined to create a fundamentally unfair trial	Court held no such errors occurred; cumulative-error claim fails and conviction stands

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance of counsel: deficient performance and prejudice)
State v. Conway, 108 Ohio St.3d 214 (2006) (failure to object does not automatically equal ineffective assistance)
State v. Hill, 75 Ohio St.3d 195 (1996) (objections can disrupt trial flow and jurors view frequent objections negatively)