State v. Glenn, 2012 Ohio 3075

Glenn was convicted at bench trial of four felonious assault counts and two aggravated robbery counts, with firearm specifications; jury found Cassano connected to the gunman via circumstantial evidence.
Prosecution presented eyewitness accounts of the shooting and police testimony describing a stocky, white, hooded man; Cassano and Glenn were linked through cell phone records and surveillance.
Investigators found a 9mm Glock linkage via shell casings and a bullet; the firearm used was not recovered.
Text messages between Glenn and a Boost Mobile recipient directed the location of the victims; those messages were authenticated and admitted.
Glenn argued insufficiency and weight of the evidence, improper admission of text-message evidence, and error in imposing consecutive firearm-term sentences.
The court affirmed, holding sufficient evidence supported convictions, text messages admissible as business records and not hearsay, and consecutive sentences properly imposed under applicable statutes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Glenn	Glenn	Convictions supported by sufficient evidence
Manifest weight of the evidence	Glenn	Glenn	Convictions not against weight of the evidence
Admission of text messages	Glenn	Glenn	Text messages properly authenticated and not hearsay; exception applied
Consecutive sentences for firearm specifications	Glenn	Glenn	Consecutive terms proper under R.C. 2929.14(D)(1)(g) and related provisions

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (sufficiency standard; proof beyond a reasonable doubt)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (circumstantial evidence allowed; standard of review)
State v. Steffen, 31 Ohio St.3d 111 (Ohio 1987) (hearsay exceptions; regular business records admissibility)
State v. Hirtzinger, 124 Ohio App.3d 40 (2d Dist. 1997) (business-record authentication for call records)
State v. Knox, 18 Ohio App.3d 36 (9th Dist. 1984) (business records rule applicability)