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State v. Dykes
2013 Ohio 872
Ohio Ct. App.
2013
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Background

  • Appellant Okema K. Dykes appeals a jury verdict convicting him of aggravated robbery and robbery under a theory of complicity, sentencing him to 17 years total.
  • Prosecution showed a planned robbery of Daniel Adkins, a Key Bank/ recycling-plant employee, with co-defendant Tyrell Hurd taking the money and Dykes driving.
  • Evidence included surveillance, a silver handgun, a struggle for bags of cash, and the suspects’ flight in a silver Jeep.
  • Appellant provided several police statements with inconsistencies; fingerprints matched the inside driver’s door of the fleeing Jeep; a silver handgun was operable.
  • Cell phones used to communicate prior to and on the day of the robbery corroborated the participants’ collaboration; Hurd testified to their joint plan and execution.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the verdict is against the manifest weight of the evidence Dykes emphasizes Hurd’s credibility and argues the state relied largely on him Dykes argues circumstantial evidence and inconsistencies undermine guilt No; evidence, including physical and documentary items, supports guilt beyond a reasonable doubt

Key Cases Cited

  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (establishes standards for manifest weight review and deference to trial court findings)
  • State v. DeHass, 10 Ohio St.2d 230 (1967) (sets framework for appellate deference to the trier of fact on witness credibility)
  • State v. Jenks, 61 Ohio St.3d 259 (1991) (guides circumstantial evidence evaluation and inference framework)
  • State v. Awan, 22 Ohio St.3d 120 (1986) (conducts credibility and weight assessment of conflicting testimony)
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Case Details

Case Name: State v. Dykes
Court Name: Ohio Court of Appeals
Date Published: Mar 11, 2013
Citation: 2013 Ohio 872
Docket Number: 2012-L-021
Court Abbreviation: Ohio Ct. App.