History
  • No items yet
midpage
State v. Hale
2012 Ohio 2662
Ohio Ct. App.
2012
Read the full case

Background

  • Hale was convicted by a jury of two counts each of Rape, Gross Sexual Imposition, Sexual Battery, and Sexual Imposition, plus two counts of Corrupting Another With Drugs; Sexual Battery counts merged with Rape.
  • He was sentenced to a prison term of 15 years to life.
  • State appeals raising three assignments of error: sufficiency of the evidence, weight of the evidence, and merger/sentencing under R.C. 2941.25.
  • State argued the evidence was legally sufficient despite uncorroborated victim accusations.
  • Appellate court addressed standards of review for sufficiency, weight, and allied-offense merger; upheld the convictions and sentence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence State contends evidence sufficed to prove elements. Hale claims State failed to prove essential elements beyond a reasonable doubt. Overruled; evidence sufficient.
Weight of the evidence State argues uncorroborated testimony supported convictions. Hale says evidence unpersuasive and not preponderant. Overruled; evidence capable of sustaining belief.
Merge of counts under R.C. 2941.25 State contends no required merger; multiple offenses may be separately punished. Hale argues counts must merge as allied offenses. Overruled; merger not compelled; convictions affirmed.

Key Cases Cited

  • State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (defines sufficiency standard)
  • State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (defines weight of the evidence standard)
  • State v. Johnson, 128 Ohio St.3d 153 (Ohio 2010) (allied offenses merger framework)
  • State v. Whitfield, 124 Ohio St.3d 319 (Ohio 2010) (merger when offenses share same conduct and animus)
Read the full case

Case Details

Case Name: State v. Hale
Court Name: Ohio Court of Appeals
Date Published: Jun 15, 2012
Citation: 2012 Ohio 2662
Docket Number: 11CA0033
Court Abbreviation: Ohio Ct. App.