State v. Griffin (Slip Opinion)
2014 Ohio 4767
Ohio2014Background
- Griffin was convicted of engaging in a pattern of corrupt activity under R.C. 2923.32; on appeal, Griffin argued ineffective assistance of appellate counsel for failing to challenge the jury instruction on “enterprise.”
- The Second District reversed Griffin’s RICO conviction after finding the jury instruction inadequate, citing State v. Franklin.
- The Ohio Supreme Court granted review to resolve whether a standard jury instruction suffices to convey the law on “enterprise” under RICO when it includes the offense elements, definitions, and the requirement to find both “enterprise” and “pattern of corrupt activity.”
- The court of appeals certified a conflict with a Ninth District decision in Habash and accepted the state's discretionary appeal.
- The majority held the jury instructions adequately conveyed the law on “enterprise,” reversed the appellate court’s reversal, and remanded for sentencing; the dissent would have affirmed the appellate court’s reversal and preferred more explicit enterprise definitions.
- Dissent argued the statutory language is too broad and a specific enterprise definition is necessary; the majority rejected this a need for additional instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the jury instruction on enterprise adequately conveyed the law | Griffin argued the instruction was inadequate and needed a Turks/Boyle-based definition. | Griffin’s argument referenced Boyle and Turkette as the proper standard. | Yes; instruction adequate and conveyed the law |
Key Cases Cited
- State v. Joy, 74 Ohio St.3d 178 (1995) (jury instructions must be correct, pertinent, timely and not redundant)
- Cincinnati v. Epperson, 20 Ohio St.2d 59 (1969) (court must give necessary instructions for jury to weigh evidence)
- State v. Comen, 50 Ohio St.3d 206 (1990) (limits on required jury instructions; necessary for factfinding)
- United States Civ. Serv. Comm. v. Natl. Assn. of Letter Carriers, AFL-CIO, 413 U.S. 548 (1973) (informational content of charges must be understood by reasonable persons)
- Boyle v. United States, 556 U.S. 938 (2009) (enterprise requires structural features: purpose, relationships, longevity)
- United States v. Turkette, 452 U.S. 576 (1981) (enterprise proved by ongoing organization and continuing unit-like operation)