State v. El-Jones, 2012 Ohio 4134

Defendant Elohim El-Jones was convicted in Summit County for aggravated murder, murder, two felonious assaults, and having weapons under disability; a gang-participation count was dismissed.
The underlying violence occurred August 14–15, 2009 in The Rosemary housing complex and at Chapel Hill Mall, involving a prior altercation and a fatal shooting of Michael Kirksey; witnesses identified El-Jones as 'Prophet'.
After the shooting, El-Jones evaded arrest for over a year until his capture in 2011; he lied about a gunshot wound to obtain a ride, which contributed to the investigation.
A courtroom closure occurred mid-trial due to intimidation concerns from El-Jones’ family and gallery spectators; the media remained allowed, and final jury instructions reopened the courtroom.
El-Jones appealed on multiple grounds, including public-trial rights, ineffective assistance, sufficiency/weight of the evidence, and sentencing-relevant procedures (costs, fees, and consideration of a suppression recording).
The trial court sentenced El-Jones to 33 years to life; on appeal, some assignments were sustained, and others were overruled, with remand for costs/fee-waiver proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Public trial closure and counsel	El-Jones argues closure violated Sixth Amendment; counsel ineffective for not challenging closure.	El-Jones asserts improper closure and ineffective assistance for failure to object.	Partial closure upheld; no reversible error; no ineffective-assistance finding.
Juror misconduct and mistrial	Jurors discussed case and questioned closure; some jurors allegedly biased.	Mistrial warranted due to juror misconduct and exposure to gallery.	No plain error; no mistrial required; jurors could continue.
Sufficiency and manifest weight	Identity proven beyond reasonable doubt; convictions supported by evidence.	Insufficient evidence and weight arguments challenging identity.	Convictions upheld; sufficient evidence and not against weight.
Costs and attorney fees	Court failed to inform of cost/fee obligations, violating R.C. 2947.23 and 2941.51.	Costs/fees properly assessed; no indigency claim properly considered.	Remanded for indigency waiver of costs and for determination of attorney-fee payment ability.
Sentencing reliance on information not in record	Sentence based on information not contained in the record; potential sentencing error.	No reversible error; information considered within statutory framework.	No reversible error; review limited by jurisdictional considerations; assignments rejected on the merits.

State v. Lane, I Ohio St.2d (1979) (public trial right is not absolute; close allowed in limited circumstances)
State v. Evans, 2008-Ohio-4295 (9th Dist.) (abuse-of-discretion review for partial closures; need substantial reason)
State v. Drummond, 111 Ohio St.3d 14 (2006) (closure must be narrowly tailored; substantial reasons with findings)
State v. Bayless, 48 Ohio St.2d 73 (1976) (trial court may exclude spectators to protect witnesses)
State v. Otten, 33 Ohio App.3d 339 (1986) (credibility and weight of witness testimony; appellate deference to jury)