State v. Griffin
138 Ohio St. 3d 108
| Ohio | 2013Background
- Griffin was indicted for aggravated murder with a capital specification and a firearm specification after the 1989 murder of James Steurer Sr.
- Griffin waived jury and was tried by a single judge; death penalty was not pursued under a pretrial agreement.
- In January 1990 Griffin was sentenced to life with parole eligibility in 30 years; guilt-phase judgment entered December 1989; no sentencing opinion filed.
- Griffin appealed in 1990; the Fifth District later held Griffin’s 1990 sentence was not final and appealed under Parker and related capital procedures.
- Griffin later sought a Baker-based resentencing in 2009; the Baker entry was declared a nullity and remanded to apply Ketterer’s rule.
- This Court ultimately held the 1990 sentencing entry was a final, appealable order and that res judicata barred relitigation via Baker resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Griffin’s 1990 sentencing entry final and appealable? | Griffin argues the 1990 entry lacked proper capital procedures and was not final. | State argues the 1990 entry was final under Ohio law at the time and reviewable. | Yes, the 1990 sentencing entry was final and appealable. |
| Does res judicata bar Griffin from Relitigating issues via Baker resentencing? | Griffin contends Baker-based relitigation is permissible for issues litigated on direct appeal. | State argues res judicata bars any relitigation from Baker-based resentencing. | Res judicata bars relitigating via Baker resentencing. |
| In capital cases, does finality require both a sentencing opinion and judgment to constitute a final order? | Griffin asserts Ketterer requires both components for finality; Baker misapplies one-document rule. | State argues final order can be found under Baker’s framework for one-document entries. | Final order requirements depend on whether sentencing opinion is filed; Baker/one-document rule inconsistent with Ketterer in this context. |
| Should the case be remanded for dismissal rather than further merits review? | Griffin asserts remand for dismissal is appropriate given finality and res judicata. | State seeks dismissal and affirmance of res judicata application. | remand to dismiss Griffin’s appeal. |
Key Cases Cited
- State v. Baker, 119 Ohio St.3d 197 (Ohio 2008) (one-document judgment rule for final, appealable order under Baker)
- State v. Ketterer, 126 Ohio St.3d 448 (2010) (final order in capital cases requires sentencing opinion and judgment)
- State v. Parker, 95 Ohio St.3d 524 (2002) (three-judge panel required when offense punishable by death, even if death not pursued)
- State v. Henry, 4 Ohio St.3d 44 (1983) (capital offense definitions and procedures; death penalty relevance)
- State v. Szefcyk, 77 Ohio St.3d 93 (1996) (final judgments and res judicata principles in Ohio)