State v. Chandler, 2017 Ohio 9279

Background

On Oct. 14, 2016 the Gameroom was robbed by two masked, gloved men; the owner/employee Brandie McGowan described the robbery but did not identify Chandler at trial.
Police traced a phone number from a witness (Shania Summerville) to a Facebook account in Chandler’s name; Summerville later confessed she was the lookout and identified Chandler as the gunman.
Amber Walters (a law-enforcement employee) corroborated that the disputed phone number belonged to Chandler and testified Chandler was on a GPS monitor the night of the robbery, but the monitor was uncharged.
Chandler was indicted for aggravated robbery with a firearm specification; a jury convicted him and the court imposed consecutive prison terms (6 years for robbery, plus a 3-year mandatory firearm spec).
On appeal Chandler raised four issues: denial of a continuance to recall a detective, admission of allegedly prejudicial testimony (Walters), sufficiency/manifest weight of the evidence, and ineffective assistance of counsel for failing to exclude/test object to Walters’ testimony and for not obtaining a mistrial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court abused discretion by denying continuance to recall detective	State: denial was within court control of docket; no prejudice shown because cell‑tower evidence was unhelpful and records were late-disclosed	Chandler: needed continuance to re-cross detective about phone records; denial deprived him of compulsory-process/due-process rights	Denial not an abuse of discretion; no due-process violation because no demonstrable prejudice
Admission of Amber Walters’ testimony was more prejudicial than probative	State: testimony corroborated Summerville, was relevant to identity and opportunity (uncharged GPS monitor)	Chandler: testimony suggested criminal history/monitoring and unfairly prejudiced jury	No plain error; testimony relevant and not unfairly prejudicial; unlikely to have affected outcome
Conviction against sufficiency and manifest weight of evidence	State: corroborating phone records, Summerville’s identification, and Walters’ corroboration provided sufficient circumstantial evidence of identity	Chandler: no physical/scientific evidence; accomplice (Summerville) unreliable and received plea deal	Sufficient evidence to support conviction; not an exceptional case for reversing on manifest weight grounds
Ineffective assistance of counsel for failing to exclude/object to Walters’ testimony or obtain mistrial	State: counsel’s failures did not prejudice outcome because testimony was admissible and court cured improper remarks with instruction	Chandler: counsel should have objected/moved in limine and sought mistrial after prosecution’s closing comment about an ankle bulge	No ineffective assistance—defense not prejudiced; objections/mistrial motion would not have changed result; court sustained objection and instructed jury to disregard

Key Cases Cited

Ungar v. Sarafite, 376 U.S. 575 (U.S. 1964) (standard for reviewing denial of continuance/abuse of discretion)
Washington v. Texas, 388 U.S. 14 (U.S. 1967) (right to compulsory process to obtain witnesses)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review—whether any rational trier of fact could find guilt beyond reasonable doubt)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong ineffective assistance of counsel test)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (circumstantial evidence has same probative value as direct evidence)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight standard)
State v. Rogers, 143 Ohio St.3d 385 (Ohio 2015) (plain‑error prejudice standard referenced in Crim.R. 52(B))
Eastley v. Volkman, 132 Ohio St.3d 328 (Ohio 2012) (every reasonable presumption in favor of the trial court on manifest‑weight review)