State v. Daniels
2012 Ohio 2000
Ohio Ct. App.2012Background
- 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)
