State v. Glenn, 2011 Ohio 3684

indicted July 6, 2009 on six counts: two aggravated robbery, two kidnapping, two theft, each with firearm specs
bench trial held October 26, 2009; witnesses described the robbery, vehicle theft, and pursuit; victims identified Glenn and OnStar tracked the vehicles
automobile chase led to Glenn's capture; Orloski's purse found in Malibu; Monte Carlo recovered later
Glenn made spontaneous statements at CPU; custodial warnings under Miranda were not required for volunteered statements
photo-array identification: Orloski identified Glenn in the fourth array after prior arrays featured his brothers; identification challenged as tainted
court granted Crim.R. 29(A) acquittal on kidnapping; convicted Glenn of two aggravated robberies, two thefts, and related firearm specifications; sentenced to six years with five years post-release control
appeal challenged trial court bias/prejudice and manifest weight of the evidence; judgment affirmed

Issue	Plaintiff's Argument	Defendant's Argument	Held
Bias or prejudice denial of fair trial	State asserts no bias; admissible evidence supported verdict	Glenn argues trial court biased by admitting improper evidence	No reversible bias; admissions proper; no error in ruling on evidence
Manifest weight of the evidence	State contends testimony and identification sufficient to sustain convictions	Glenn contends tainted evidence undermines verdict	Conviction not against weight of the evidence

State v. Bays, 87 Ohio St.3d 15 (1999) (bench trial evidence relevance presumption of admissibility of evidence)
Pratt v. Weygandt, 164 Ohio St. 463 (1956) (bias standard; judge presumed unbiased absent strong contrary showings)
In re Disqualification of Murphy, 36 Ohio St.3d 605 (1988) (disqualification; bias not presumed from legal rulings)
Nakoff v. Fairview Gen. Hosp., 75 Ohio St.3d 254 (1996) (abuse of discretion standard for evidentiary rulings)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (weight of the evidence; discretionary review for manifest injustice)