State v. Goldblum, 2014 Ohio 5068

Goldblum was convicted of eight counts of Rape (under 13), two counts of Unlawful Sexual Conduct with a Minor, two counts of Voyeurism, one count of Attempted Voyeurism, and two counts of Menacing by Stalking involving his niece and several of her friends.
The State alleged a pattern of molestation during sleepovers over nearly a decade at Goldblum's home, where victims awoke to Goldblum lifting blankets, removing clothing, and exposing or touching their genitalia.
Goldblum moved to sever the counts; the court initially granted severance but later reconsidered and overruled severance in light of a related Supreme Court decision.
During trial, several counts were dismissed; the jury ultimately found Goldblum guilty on thirteen counts, leading to a multi-count prison sentence and designation as a sex offender.
The trial court imposed consecutive sentences for certain counts, but the judgment entry did not incorporate the statutory findings required for consecutive sentences, prompting remand for a nunc pro tunc order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for Voyeurism	Goldblum asserts evidence fails to prove purpose element.	Goldblum argues no credible proof of arousal purpose or trespass.	Sufficient evidence supported purpose and intrusion elements; convictions upheld.
Convictions against manifest weight	Weights rely on credible victim testimony; no physical corroboration required.	Testimony contradicted; other witnesses’ accounts render verdicts against weight of evidence.	Not against the manifest weight; jury credibility findings affirmed.
Severance/joinder	Joinder proper under Crim.R. 8; evidence of other acts admissible to prove intent and plan.	Prejudicial joinder and need for severance.	Trial court did not err in overruling severance; other acts evidence properly admitted and limited.
Leading questions and trial court's definition	State used leading questions improperly; court misdefined leading questions.	Leading questions were pervasive and prejudicial.	No reversible error; record does not establish prejudicial leading-question error.
Consecutive-sentencing findings	Court failed to include statutory findings in the judgment entry.	Findings were made at sentencing; omission in entry was error.	Consecutive-sentence findings made at sentencing; remanded for nunc pro tunc entry to reflect them.

State v. Bonnell, 140 Ohio St.3d 209 (2014-Ohio-3177) (consecutive-sentence findings must be included in judgment entry)
State v. Williams, 134 Ohio St.3d 521 (2012-Ohio-5695) (joinder and admissibility of other-acts evidence; evaluation framework)
State v. LaMar, 95 Ohio St.3d 181 (2002-Ohio-2128) (joinder/severance analysis under Crim.R. 8 and 14)
State v. Lott, 51 Ohio St.3d 160 (1990) (joinder of offenses; direct/simple evidence standard for prejudice)
State v. Torres, 66 Ohio St.2d 340 (1981) (joinder/severance principles related to multiple offenses)
State v. Kirkland, 140 Ohio St.3d 73 (2014-Ohio-1966) (other acts admissibility under Evid.R. 404(B) and R.C. 2945.59)
State v. Morris, 2012-Ohio-2407 (Ohio Supreme Court) (trial court discretion on evidentiary rulings; balancing probative value vs. prejudice)
State v. DeHass, 10 Ohio St.2d 230 (1967) (trial court credibility determinations are within the jury's province)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest weight standard; review of entire record)
State v. Martin, 20 Ohio App.3d 172 (1985) (weight of the evidence and witness credibility are jury determinations)
State v. Williams, 134 Ohio St.3d 521 (2012-Ohio-5695) (404(B) purposes and admissibility of other-act evidence)