State v. Flowers, 2012 Ohio 3783

Arrested on Aug. 12, 2010 after violent confrontation with girlfriend;
Indicted Aug. 26, 2010 for felonious assault, cocaine possession, cocaine trafficking, domestic violence, and protection-order violation;
Bifurcation granted regarding repeat violent offender;
Jury convicted Flowers on multiple counts;
Court found repeat violent offender, merged some counts, and sentenced Flowers to 13 years and forfeiture;
Appeal followed challenging trial counsel and evidentiary rulings;

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for not suppressing pre-Miranda statement	Flowers argues trial counsel failed to move to suppress	State contends no valid suppression basis existed	No reversal; evidence independent of statement supported conviction
Admissibility of hearsay and related statements	Flowers claims multiple hearsay errors in testimony and records	State asserts exceptions and admissibility standards apply	No reversal; numerous exceptions upheld and prejudice not shown
Denial of mistrial for handcuff observations	Two jurors saw Flowers in handcuffs outside courtroom; mistrial requested	Court did not abuse discretion; viewing was brief and outside courtroom	No reversal; denial of mistrial affirmed

State v. Reynolds, 80 Ohio St.3d 670 (1998) (two-prong Strickland standard for ineffective assistance)
State v. Keith, 79 Ohio St.3d 514 (1997) (defendant must show deficient performance and prejudice)
State v. Adams, 103 Ohio St.3d 508 (2004) (valid suppression basis required for ineffective assistance claim)
State v. Huertas, 51 Ohio St.3d 22 (1990) (excited utterance exception to hearsay for shock and immediacy)
State v. Wallace, 37 Ohio St.3d 87 (1988) (requirements for excited utterance and non-cumulative testimony)
State v. Franklin, 97 Ohio St.3d 1 (2002) (restrained appearance impact on fair trial; focus on curative measures)
Estelle v. Williams, 425 U.S. 501 (1976) (trial in prison attire violates due process; may be prejudicial)