State v. Connally, 2016 Ohio 7573

January 8, 2015 home invasion at an apartment: multiple masked men entered, one held a black-and-silver semi-automatic pistol to victims, ordered them to a closet, and others took property. Victims D.W. and her brother L.G. were present.
Four witnesses (victims D.W. and L.G., participant C.F., and codefendant identifications) identified appellant Jahmez Connally as the gunman; Connally denied possessing a gun but admitted dropping off and picking up others near the scene.
Police recovered ten photographs from Connally’s cell phone showing Connally holding, and close-ups of, a black-and-silver pistol and other firearms.
Connally was indicted on aggravated burglary, aggravated robbery, robbery, and kidnapping counts with firearm specifications; a jury convicted on all counts and specifications.
Connally appealed arguing (1) the trial court abused its discretion admitting photographs M1–M10 and (2) the convictions were not supported by sufficient evidence and were against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of cell-phone photographs (M1–M10)	Photos are relevant to show Connally owned/possessed a gun matching the gunman’s description and rebut his denial.	Photos were inflammatory and unfairly prejudicial; some images show guns not used in the crime and invite juror prejudice.	Admission was not an abuse of discretion: pics were relevant, probative value outweighed prejudice.
Sufficiency and manifest weight of evidence on identity	Victim identifications, accomplice testimony (C.F.), and phone photos provide sufficient, credible evidence to support verdicts.	Witness identifications were unreliable; accomplice testimony tainted by plea deal; lack of physical evidence linking Connally.	Convictions supported by sufficient evidence and not against manifest weight; jury entitled to resolve credibility in favor of prosecution.

State v. Issa, 93 Ohio St.3d 49 (Ohio 2001) (standard for admission of evidence and appellate review of evidentiary rulings)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse of discretion standard)
State v. Crotts, 104 Ohio St.3d 432 (Ohio 2004) (definition and limits of unfair prejudice under Evid.R. 403)
Oberlin v. Akron Gen. Med. Ctr., 91 Ohio St.3d 169 (Ohio 2001) (discussion of unfair prejudice meaning)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (sufficiency and manifest weight standards)
State v. Tenace, 109 Ohio St.3d 255 (Ohio 2006) (standard for reviewing sufficiency of evidence)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (jury as trier of fact on credibility)
Tibbs v. Florida, 457 U.S. 31 (U.S. 1982) (appellate court’s role when reversing on manifest-weight grounds)