State v. Hall, 2017 Ohio 73

On Oct. 22–23, 2014, tenant Wayne Douglas discovered a broken window and missing property from his Akron rental; later he encountered Brett Hall and Larry White inside his home and identified them to police.
Police stopped a van driven by Hall (White and Rachael Kerns were passengers) twice in short order; officers seized a suitcase and other items from the van that Douglas identified as his property.
Hall and White were indicted and tried jointly for burglary in violation of R.C. 2911.12(A)(2); the jury convicted both.
Hall was sentenced to four years’ imprisonment and three years of post-release control; he appealed raising three assignments of error.
The court affirmed, rejecting Hall’s challenges to sufficiency/manifest weight, alleged prosecutorial misconduct during rebuttal closing, and a Batson challenge to a peremptory strike.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency / manifest weight of the evidence (burglary)	Hall: evidence insufficient and verdict against manifest weight; Kerns had authority/permission; Douglas not lawful resident.	State: Douglas legally occupied the residence; Kerns had turned in key and denied permission; stolen property was found in van driven by Hall.	Conviction supported by sufficient evidence and not against manifest weight.
Prosecutorial misconduct in rebuttal closing	Hall: prosecutor referenced evidence not in record, vouched for witnesses, commented on defendant's silence, and disparaged defense counsel.	State: remarks were supported by record or were permissible argument; trial court cured/disregarded improper remark and no plain error shown.	No reversible misconduct; objection sustained/curative instruction given where appropriate; no prejudice shown.
Batson challenge to peremptory strike	Hall: prosecution struck an African‑American juror for racially discriminatory reasons; trial court misapplied Batson three‑step test.	State: offered race‑neutral reason (juror worked in Head Start / helping profession) and struck non‑black jurors for similar reasons; no pattern of discrimination.	Trial court did not err: Hall failed to make a prima facie showing and the proffered reason was race‑neutral; no clear error in finding no discriminatory intent.

State v. Thompkins, 78 Ohio St.3d 380 (establishes difference between sufficiency and manifest weight review)
State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency review: whether any rational trier of fact could find essential elements proven)
State v. Otten, 33 Ohio App.3d 339 (standard for manifest weight review—court may reverse only in exceptional cases)
State v. Urbin, 148 Ohio App.3d 293 (conflicting evidence alone does not make verdict against manifest weight)
State v. Lott, 51 Ohio St.3d 160 (reviewing prosecutorial misconduct claims in context of entire trial record)
Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory challenges; three‑step Batson framework)
Miller‑El v. Dretke, 545 U.S. 231 (courts must assess plausibility of prosecutor's explanation in light of all evidence)
State v. Murphy, 91 Ohio St.3d 516 (discusses Batson analysis and use of facially neutral reasons)
State v. Pickens, 141 Ohio St.3d 462 (trial court’s credibility determinations in Batson inquiry are entitled to deference)