State v. Evans
2017 Ohio 8184
| Ohio Ct. App. | 2017Background
- On April 8–9, 2015, a 21‑month‑old child in Dionte Evans’s care suffered massive internal abdominal injuries and later died; autopsy found blunt‑force trauma to the torso (liver lacerations and internal bleeding). Evans was the only adult present and initially told officers the child hit his head while playing.
- After autopsy results contradicted the head‑injury account, Evans admitted in a police interview he had punched the child during “play fighting.” He was arrested and taken to jail.
- While being booked, Evans made statements to a receiving officer (Raiff) and a jail paramedic (Jeffries): to Raiff he said, "I had killed my son" and when asked “what happened” said he punched the child and caused internal bleeding; to Jeffries he said he had "accidentally killed his son." Detective interviews with Miranda waivers also contained admissions that Evans struck the child.
- A jury convicted Evans of felony murder (and related counts merged for sentencing); the trial court sentenced him to 15 years to life. Evans appealed raising six assignments of error: judicial bias, denial of suppression of booking statements, Batson challenge, admissibility of coroner as expert, sufficiency, and weight of the evidence.
- The trial court denied suppression of the booking statements (finding either no interrogation or that Miranda waiver remained effective and booking‑question exception applied); it admitted deputy coroner Castro as an expert; it allowed the prosecutor’s peremptory strike after a race‑neutral explanation; and the jury verdict/sentence were affirmed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Evans) | Held |
|---|---|---|---|
| Judicial bias | No bias; rulings and scheduling did not deprive due process | Judge showed bias by pressuring expeditious resolution and through rulings | Court: No evidence of disqualifying bias; assignment overruled |
| Suppression of booking statements to Raiff | Statements admissible: prior Miranda waiver still effective; initial question about charges was routine booking question; even if error, admission was harmless given other unchallenged admissions | Raiff’s questions were interrogation likely to elicit incriminating responses; Miranda warnings required and statements should be suppressed | Court: Miranda waiver still effective; charging question fit booking exception; even if improper, admission was harmless; assignment overruled |
| Batson peremptory strike of an African‑American juror | Strike supported by race‑neutral reasons (medical condition/medication, tendency to nod off, relative prosecuted locally) | Strike was pretextual and lacked race‑neutral basis | Court: Prosecutor articulated credible race‑neutral reasons; Batson challenge overruled |
| Coroner’s expert testimony | Castro qualified by medical training, fellowship in forensic pathology, thousands of autopsies, prior expert testimony | Lacked board certification, thus unqualified | Court: Board certification not required; Castro qualified as expert; testimony admissible |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (establishes three‑step test for race‑based peremptory challenges)
- Pennsylvania v. Muniz, 496 U.S. 582 (recognizes routine booking question exception to Miranda)
- State v. Hale, 119 Ohio St.3d 118 (Ohio Supreme Court on booking‑question exception applicability)
- State v. Powell, 132 Ohio St.3d 233 (addresses when prior Miranda warnings remain effective)
- State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency of the evidence review)
- State v. Thompkins, 78 Ohio St.3d 380 (standard for manifest‑weight review)
- State v. Dean, 127 Ohio St.3d 140 (discussion of judicial bias and due process)