State v. Halley, 2012 Ohio 1625

Zachary Halley was convicted by a jury of breaking and entering a building (Clifford's Auto Parts) and aggravated robbery (Dollar General).
Evidence linked Halley to both crimes: removal of catalytic converters from Clifford’s out-building and later sale of the converters to L & L.
Dollar General surveillance and employee identifications, plus fingerprint analysis on a Pepsi bottle, connected Halley to the robbery.
The trial court sentenced Halley to 12 months for breaking and entering and 10 years for aggravated robbery, to be served consecutively (11-year total).
Halley appealed, raising claims of hearsay, ineffective assistance of counsel, manifest weight, sufficiency of evidence, and cumulative error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plain error from hearsay	Halley contends officer testimony about Cutlip's identification was hearsay.	Halley asserts admission of this identification violated evidentiary rules and affected guilt.	No plain error; evidence otherwise sufficiently supports guilt.
Ineffective assistance of counsel	Halley argues counsel prevented alibi/testimony and failed to move for acquittal.	Counsel’s actions were strategic; no demonstrated prejudice.	No reversible ineffectiveness; defense not shown to prejudice outcome.
Sufficiency of the evidence	State asserts sufficient direct/circumstantial evidence ties Halley to both crimes.	Halley contends evidence is weak/circumstantial and fails to prove elements beyond a reasonable doubt.	Evidence is sufficient to sustain both convictions.
Manif est weight of the evidence	State argues credibility and probabilities support convictions.	Halley claims the verdict contradicts the weight of the evidence, especially for the burglary/entering charge.	Convictions not against the manifest weight; trial court did not lose its way.
Cumulative error	State contends no reversible error occurred cumulatively.	Halley asserts cumulative errors deprived him of a fair trial.	Cumulative error doctrine inapplicable; no prejudicial error established.

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for sufficiency after viewing evidence in light most favorable to the prosecution)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (circumstantial evidence has same probative value as direct evidence)
State v. Were, 118 Ohio St.3d 448 (Ohio 2008) (identification-related reliability considerations in evidence)
State v. Hancock, 108 Ohio St.3d 57 (Ohio 2006) (probative value of evidence and standard for appellate review)
State v. Earle, 120 Ohio App.3d 457 (Ohio App. 1997) (manifest weight standard on appeal)
State v. Williams, 73 Ohio St.3d 153 (Ohio 1995) (witness credibility and weight of evidence considerations)
State v. Dye, 82 Ohio St.3d 323 (Ohio 1998) (weight of evidence and credibility doctrine)
State v. White, 82 Ohio St.3d 16 (Ohio 1998) (prejudice analysis for harmless-error review)
State v. Braden, 98 Ohio St.3d 354 (Ohio 2003) (prejudice requirement in ineffective assistance review)
State v. Sanders, 92 Ohio St.3d 245 (Ohio 2001) (harmless-error and prejudice standards in appellate review)
State v. Conway, 108 Ohio St.3d 214 (Ohio 2006) (harmless-error doctrine application)