State v. Frazier, 2012 Ohio 790

Frazier was charged in Summit County with felonious assault and related offenses based on Oct. 8–10, 2008 incidents at 542 Tennessee Place, Barberton.
Witnesses described Frazier firing a gun toward the victim’s residence and making threatening voicemails.
The State introduced surveillance video, shell casings, a live bullet, and a threat-laden voicemail corpus.
Frazier admitted being present but claimed another man fired the shots; he was convicted by a jury on several counts.
Frazier was sentenced to a composite term of ten years, with some counts concurrent and others consecutive.
The court of appeals affirmed the convictions and rejected all assigned errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court used the correct standard to excuse for-cause juror bias	Frazier argues Batson-based standards were misapplied	State contends R.C. 2945.25(B)/Crim.R. 24(C) governs, not Batson	Correct standard applied; assignment overruled
Whether removing a juror for bias was an abuse of discretion	Frazier claims improper for-cause removal violated due process	Court properly excused for-cause based on bias	No abuse of discretion; assignment overruled
Whether removal of an African American juror violated equal protection	Batson concerns—racial discrimination in peremptory challenges	Removal was for-cause, not a peremptory strike; non-dispositive	Assignment overruled; no Batson violation established
Whether removal of a Spanish-speaking juror for language reasons was improper	Language barrier evidence was insufficient to justify removal	Court acted under Crim.R. 24(B)(13) and R.C. 2945.25(N)	Removal justified; assignment overruled
Whether evidence was sufficient and the verdict not against weight	State failed to prove Frazier fired a handgun and caused imminent harm	Witnesses saw shots; voicemail threats; physical evidence supported guilt	Sufficiency and weight claims overruled; convictions sustained

State v. Cornwell, 86 Ohio St.3d 560 (1999) (trusty standard for juror challenges; deference to trial court on credibility)
Med. Mut. of Ohio v. Schlotterer, 122 Ohio St.3d 181 (2009) (abuse-of-discretion de novo when interpreting law)
State v. Moss, — (2009) (Batson vs for-cause standard distinction clarified (permissible inquiry))
State v. Getsy, 84 Ohio St.3d 180 (1998) (Crim.R. 24(B)(13) language barriers validity)
Jenks, 61 Ohio St.3d 259 (1991) (sufficiency standard for criminal conviction)
Batson v. Kentucky, 476 U.S. 79 (1986) (prohibition of race-based peremptory challenges)
Hernandez v. New York, 500 U.S. 352 (1991) (race-neutral explanations for peremptory challenges)
Powers v. Ohio, 499 U.S. 400 (1991) (extends Batson to cross-racial juries)
State v. Johnson, 31 Ohio St.2d 106 (1972) (impartial jury not required to include all groups)
State v. Murphy, 91 Ohio St.3d 516 (2001) (impartial jury right; weigh credibility of witnesses)
State v. Haines, 112 Ohio St.2d 393 (2006) (limitations on cycle-of-violence testimony; rehabilitative purpose)
State v. Getsy, 84 Ohio St.3d 180 (1998) (Crim.R. 24(B) language barrier standards)
State v. Group, 98 Ohio St.3d 248 (2002) (deference to trial court on juror qualification)
State v. DePew, 38 Ohio St.3d 275 (1988) (credibility in juror bias determinations)