State v. Davis, 2013 Ohio 5226

Davis was convicted of felony murder and aggravated robbery arising from a January 10, 2012 plan to rob Minter, with Williams and Carr involved and Davis driving the getaway.
Williams testified that Carr shot Anderson during the robbery; Davis drove Williams to a relative’s house and later picked up Carr, with the trio dividing proceeds.
The State relied on complicity (aiding and abetting) to prove both felony murder and aggravated robbery; Davis did not need to possess a firearm.
The jury acquitted Davis of weapons-under-disability and firearm specifications but found him guilty of the principal offenses.
The trial court merged felony murder and aggravated robbery and sentenced Davis to 15 years to life; this appeal followed, raising multiple assignments of error.
The court consolidates and analyzes the assignments, upholding the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence suffices to support felony murder and aggravated robbery.	Davis argues insufficient evidence and weight issues.	Davis asserts inconsistent verdicts show insufficiency.	Convictions affirmed; evidence sufficient; not against weight.
Whether acquittal on firearm specifications undermines the felonies.	Davis contends inconsistent verdicts invalidate the principal offenses.	Acquittal on specs does not undermine sufficiency of principal offenses.	No reversal; acquittals on specs do not negate principal-offense convictions.
Whether joinder and co-defendant trial prejudiced Davis such that severance was required.	In a joint trial, Davis was prejudiced by Carr’s stronger case.	No demonstrated prejudice; joinder proper under Crim.R. 8; severance not warranted.	No prejudice shown; severance not required.
Whether trial counsel was ineffective for not moving to sever.	Failure to seek severance prejudiced Davis.	No demonstrated prejudice from joinder.	Ineffective-assistance claim failed; not demonstrated.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (sufficiency/weight standard; de novo review of sufficiency; witness credibility engages weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency standard: rational trier of fact could find elements beyond reasonable doubt)
State v. Johnson, 93 Ohio St.3d 240 (2001) (aider and abettor intent may be inferred from presence and conduct)
State v. Otten, 33 Ohio App.3d 339 (1986) (weight of the evidence; appellate thirteenth juror concept)