State v. Driggins, 2012 Ohio 5287

Defendant was convicted of murder, aggravated robbery, and aggravated burglary arising from Rankin’s killing during a Rankin home burglary; he was sentenced to life with parole eligibility after 38 years, later corrected after Baker.
Defendant initially provided statements exculpating himself, then confessed after meetings with Ginn and police; multiple Miranda waivers occurred.
Ginn, a mentor figure, facilitated a written statement; police denied coercion and asserted Ginn acted independently.
At trial, the jury convicted on multiple counts including felony murder theories and firearm specifications; sentences were imposed consecutively.
Defendant appealed raising 22 assignments of error, including suppression, Sixth Amendment issues, evidentiary rulings, jury instructions, allied offenses, and sentencing challenges, all affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Suppression of March 5 and 14 statements	Driggins’ statements were voluntary and properly Miranda-waived	Statements were coerced or improperly induced; Miranda rights not properly administered	Overruled: statements voluntary; waivers valid; no due process violation
Inducement and agent issue with Ginn	Ginn not an agent of the state; defendant initiated contact	Ginn coerced or induced confession on behalf of authorities	Overruled: no coercion; Ginn not an agent; voluntariness sustained
Sixth Amendment right to counsel during interrogation	Interviews occurred after initiation of proceedings; counsel not required	Counsel should have been present; interrogation violated	Overruled: Sixth Amendment not violated; proceedings had not yet invoked right to counsel at relevant times
Alleged illegal arrest and suppression grounds	Arrest justified; Terry-like stop supported by probable cause	Arrest unconstitutional; illegal stop	Overruled: arrest supported; suppression rejected
Constitutional public-trial right and witness intimidation	Court properly closed portions to prevent intimidation	Closure violated public trial right	Overruled: court acted within discretion to protect witnesses; closure proper

State v. Polk, 8th Dist. No. 84361, 2005-Ohio-774 (Ohio App. 8th Dist. 2005) (standard for mixed questions of law and fact on suppression review)
State v. Fry, 125 Ohio St.3d 163 (2010-Ohio-1017) (felony-murder predicate mens rea governed by underlying felony)
State v. Hanna, 95 Ohio St.3d 285 (2002-Ohio-2221) (intervening causes instruction adequate; intervening act theory)
State v. Evans, 122 Ohio St.3d 381 (2009-Ohio-2974) (definition and scope of lesser included offenses; involuntary manslaughter relation)
State v. Whitfield, 124 Ohio St.3d 319 (2010-Ohio-2) (state elects allied-offense conduct for sentencing; non-allied offenses may be sentenced separately)