State v. Davis, 2014 Ohio 5260

Christopher L. Davis (defendant) is the father of D.W.; D.W. moved in with him at age 13 in 2009.
D.W. testified Davis repeatedly forced her to engage in sexual acts (including anal sex and oral contact) over several months and that threats prevented earlier reporting.
B.C., a friend who slept over once at age 13, testified Davis dragged her to the basement, raped her, and threatened to kill her if she told.
Both victims waited roughly two years before reporting; no physical or forensic evidence was introduced at trial.
A grand jury indicted Davis on two counts of rape; a jury convicted him and the trial court imposed consecutive 10-year prison terms on each count.
On appeal, Davis raised three assignments of error: (1) convictions against manifest weight of the evidence, (2) sentencing error for failing to incorporate consecutive-sentence findings in the journal entry (and allied-offenses argument), and (3) exclusion of a police report under Evid.R. 803(8).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the conviction against the manifest weight of the evidence?	State: jury properly credited victims’ testimony; credibility/resolution of inconsistencies is for the jury.	Davis: convictions rest solely on victim testimony, delayed reporting, inconsistencies, lack of physical corroboration, and implausibility.	Court: Overruled — not an extraordinary case; jury’s credibility determinations stand.
Did the trial court err by failing to include R.C. 2929.14(C)(4) consecutive-sentence findings in the sentencing entry?	State: oral findings were made at sentencing; clerical omission can be corrected by nunc pro tunc.	Davis: journal must reflect the statutory findings; absence requires remand.	Court: Remanded for nunc pro tunc entry to incorporate findings; otherwise sentence affirmed.
Should the police report (officer’s interview of B.C.) have been admitted under Evid.R. 803(8)?	Davis: Evid.R. 803(8) allows law-enforcement records offered by defendant; report should have been admitted.	State: report hearsay; trial court excluded it.	Court: Overruled — appellant failed to develop relevancy/prejudice argument on appeal; exclusion affirmed.

State v. Otten, 33 Ohio App.3d 339 (9th Dist.) (standard for manifest-weight review)
State v. Thompkins, 78 Ohio St.3d 380 (weight of the evidence and appellate "thirteenth juror" role)
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings at sentencing and incorporate them into the journal; clerical omissions may be corrected by nunc pro tunc)
State v. Awan, 22 Ohio St.3d 120 (appellate review waiver where issues not raised at trial)
State v. Childs, 14 Ohio St.2d 56 (preservation of error rule)
State v. Underwood, 124 Ohio St.3d 365 (2010) (imposition of multiple sentences for allied offenses is plain error)