State v. Hale
2012 Ohio 2662
Ohio Ct. App.2012Background
- 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)
