State v. Hampton
2016 Ohio 5321
Ohio Ct. App.2016Background
- On December 30, 2013, Carl Hampton punched Eugene Warner once in the jaw at a bar; surveillance and eyewitnesses confirm the blow and immediate fall. Warner later developed vomiting and headaches, underwent emergency surgery for a subdural hematoma, and died from intracranial bleeding while on anticoagulation medication.
- Hampton was indicted for murder (R.C. 2903.02(B)), felonious assault (R.C. 2903.11(A)(1)), involuntary manslaughter (R.C. 2903.04(B)), and assault (R.C. 2903.13(A)).
- At trial the jury initially deadlocked on murder and felonious assault, but after additional instructions returned guilty verdicts on all counts. The trial court merged counts and sentenced Hampton to 15 years to life on the murder count.
- On appeal Hampton argued insufficiency and weight of the evidence, Batson challenge to prosecution’s peremptory strikes, ineffective assistance, improper fine, prosecutorial election of allied offenses, and failure to call a defense expert. The appellate court addressed only sufficiency and Batson issues, finding the rest moot.
- The court concluded the evidence was sufficient to support that Hampton knowingly caused serious physical harm (felonious assault) and that the assault proximately caused Warner’s death, but it reversed because the prosecution failed to give a race- or gender-neutral reason for one peremptory strike of an African‑American female juror, requiring a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for felonious assault/murder (did single punch constitute knowingly causing serious physical harm and proximately cause death?) | State: single punch to head/jaw caused subdural hematoma; medical testimony said light-to-moderate force could cause the injury and anticoagulation did not break causation. | Hampton: single punch by an untrained assailant to similarly sized victim is at most reckless; intervening medical condition (anticoagulation, possible food poisoning) breaks causation. | Court: Evidence sufficient — reasonable juror could find Hampton knowingly caused serious physical harm and that the punch proximately caused death. Convictions supported. |
| Batson challenge to prosecution’s pattern of peremptory strikes (race/gender discrimination) | State: offered race- and gender-neutral reasons for several strikes and noted a struck juror was replaced by a similarly demographically situated juror. | Hampton: pattern of strikes targeted Hispanic, white, and African‑American jurors; prosecution failed to provide neutral reason for the strike of one African‑American female. | Court: Reversed — prosecution failed to articulate a race- or gender-neutral reason for the African‑American female strike; error is structural and warrants new trial. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (prosecutor may not use peremptory strikes to exclude jurors solely on account of race)
- J.E.B. v. Alabama ex rel. T.B., 511 U.S. 127 (peremptory strikes based on gender impermissible)
- Snyder v. Louisiana, 552 U.S. 472 (striking even a single juror for discriminatory purpose violates Equal Protection)
- Miller-El v. Cockrell, 537 U.S. 322 (trial court must assess plausibility of prosecutor’s race-neutral explanations)
- State v. McKnight, 107 Ohio St.3d 101 (Ohio standard for sufficiency review quoting Jenks)