History
  • No items yet
midpage
State v. Daniels
2012 Ohio 2000
Ohio Ct. App.
2012
Read the full case

Background

  • E.H., age 12, discovered pregnancy; abortion at 17.4 weeks; DNA test later confirmed Daniels as the father.
  • Daniels, 64, lived upstairs in a duplex where E.H. frequently babysat and borrowed items.
  • Trial: Daniels accused of rape; jury found him guilty; sentenced to ten years in prison.
  • Prosecution presented E.H.’s testimony of forced vaginal intercourse.
  • DNA testing showed a 99.99% probability Daniels was the father of E.H.’s baby.
  • Daniels argued the verdict was against the manifest weight of the evidence and challenged a hearsay letter admitted at trial.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Manifest weight of the evidence Daniels argues the evidence weights against conviction. State maintains evidence supports jury’s credibility determinations. Overruled; conviction not against weight of the evidence.
Hearsay and Confrontation Clause issue Daniels contends letter identifying him was inadmissible hearsay. State asserts proper admission; no contemporaneous objection preserved plain error. Overruled; plain error not addressed; no merit found.

Key Cases Cited

  • State v. Otten, 33 Ohio App.3d 339 (9th Dist.1986) (weight of the evidence standard; thirteenth juror could apply)
  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (weight-of-the-evidence standard; credibility evaluation)
  • State v. Martin, 20 Ohio App.3d 172 (1st Dist.1983) (exceptional case for weight reversal)
  • State v. Cross, 2011-Ohio-3250 (9th Dist.2011) (contemporaneous objection requirement; plain error review)
  • State v. DeWerth, 2012-Ohio-1384 (9th Dist.2012) (DNA evidence credibility; appellate review of weight)
  • State v. Arnold, 2009-Ohio-2108 (9th Dist.2009) (plain-error review limitation; forfeiture)
  • State v. Long, 53 Ohio St.2d 91 (1978) (plain-error review standard and exceptional circumstances)
Read the full case

Case Details

Case Name: State v. Daniels
Court Name: Ohio Court of Appeals
Date Published: May 7, 2012
Citation: 2012 Ohio 2000
Docket Number: 11CA010021
Court Abbreviation: Ohio Ct. App.