State v. Chapman
190 Ohio App. 3d 528
| Ohio Ct. App. | 2010Background
- Chapman, a 14-year-old, participated in a nighttime robbery of Fiske with Smith and English; English was shot and died from internal bleeding within an hour.
- Chapman was charged with multiple offenses; after initial conviction, this court reversed, and he was retried and convicted again with a 30-to-life sentence.
- Chapman argues errors including juvenile transfer, mother’s right to counsel before interrogation, Smith’s testimony, and sentence increase for going to trial.
- Law-of-the-case doctrine barred certain appellate arguments from being relitigated on retrial because they were argued in the prior appeal.
- The court affirmed most convictions, but vacated the sentence due to appearance that Chapman was punished for exercising his right to a jury trial, and remanded for resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether law-of-the-case bars the claimed errors | Chapman | Chapman | Barred by law-of-the-case |
| Whether the trial judge’s impartiality was properly preserved | Chapman | State | Plain-error claim rejected on record; no reversible impartiality issue found |
| Whether Smith’s testimony at retrial violated due to prior improper plea reliance | Chapman | State | Testimony allowed; no law-of-the-case bar; plea agreement not contingent on Chapman’s conviction |
| Whether there was sufficient/weighty evidence for murder | Chapman | State | Sufficient evidence; not against weight; proximate cause established |
| Whether Chapman’s sentence violates the right to trial by jury | Chapman | State | Sentence vacated due to appearance of punishing trial choice; remanded for new sentencing |
Key Cases Cited
- Nolan v. Nolan, 11 Ohio St.3d 1 (1984) (law-of-the-case precludes new arguments on retrial unless new)
- Sauline v. Hubbard, 74 Ohio St.3d 402 (1996) (issue preclusion on retrial for arguments not raised on first appeal)
- Murphy v. state, 91 Ohio St.3d 516 (2001) (plain-error review of potential discriminatory motive in jury selection)
- State v. Were, 118 Ohio St.3d 448 (2008) (three-step Batson framework; deference to trial court credibility findings)
- State v. Bryan, 101 Ohio St.3d 272 (2004) (Batson framework; racially neutral explanations required)
- State v. Morris, 159 Ohio App.3d 775 (2005) (sentence for exercising right to trial; appearance of punishment requires remand)
- State v. Scalf, 126 Ohio App.3d 614 (1998) (sentencing in light of trial-right assertion; caution against chilling effect)