State v. Cheatham, 2025 Ohio 2584

Adam Cheatham was convicted on nine counts of Gross Sexual Imposition against three victims (two teenage boys, E.J. and Z.C., and one female minor, S.R.), based on events between 2013 and 2023.
E.J. and Z.C. lived with Cheatham, who allegedly provided alcohol and exerted subtle control, while S.R. was much younger and lived with Cheatham and her mother for over a decade.
Cheatham was sentenced to consecutive terms totaling 27.5 years in prison; at trial he denied any inappropriate contact, claimed innocence, and alleged victims misconstrued events or retaliated against him.
On appeal, Cheatham challenged the sufficiency of evidence (particularly the force element and dates of specific offenses), the lawfulness of consecutive sentencing, and the effectiveness of his counsel.
The appellate court found that most convictions were supported by sufficient evidence, except for Count Three (relating to S.R. in 2014, where testimony did not support the specific timeframe charged); also, a remand for resentencing was ordered to properly include all required consecutive sentence findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency—Force element in Gross Sexual Imposition	Evidence showed Cheatham compelled minors by force or subtle psychological means	No evidence of force/power imbalance; testimony "murky" or not credible	Evidence sufficient on all but one count; psychological force/control over minors established
Sufficiency—Proof of dates for specific offenses	Victim’s general testimony about pattern of abuse is sufficient for dates	State failed to prove specific dates/timeframes charged in indictment	Conviction for Count Three (2014 offense) vacated due to lack of supporting evidence
Consecutive sentencing—statutory findings	Sentencing considered all appropriate statutory factors	Trial court failed to make all statutorily mandated findings in entry	Remand for resentencing to include all statutory findings
Ineffective assistance of counsel	No evidence trial counsel failed to investigate, prepare, or pursue reasonable defense	Counsel failed to investigate, cross-examine, or request lesser-included instructions/defense	No deficiency shown; most arguments speculative or strategic; no prejudice established

State v. Eskridge, 38 Ohio St.3d 56 (standard for proof of force and authority figure in child sex abuse cases)
State v. Dye, 82 Ohio St.3d 323 (requires force above inherent in offense but recognizes subtle force for authority figures)
State v. Bonnell, 140 Ohio St.3d 209 (trial court must make and incorporate findings for consecutive sentences)
Strickland v. Washington, 466 U.S. 668 (test for ineffective assistance of counsel)