State v. Ingram, 2012 Ohio 333

Ingram was convicted of murder and related offenses in Summit County; DNA testing procedures followed after conviction.
In 2010, Ingram filed an application for DNA testing under R.C. 2953.72 arguing a pubic hair might support his claim of sexual assault.
The trial court denied the application in 2011, and Ingram timely appealed the denial.
The court of appeals reviews the trial court’s legal conclusions de novo.
R.C. 2953.71–2953.74 govern postconviction DNA testing for eligible inmates who did not have prior DNA testing or whose results were inconclusive.
To obtain testing, an applicant must show that DNA exclusion would have been outcome determinative at trial; Ingram sought to show DNA inclusion instead.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of new DNA testing was outcome determinative	Ingram argued testing would prove his innocence by excluding his DNA.	State argued inclusion would not prove outcome determinative under the statute.	No; exclusion not shown to be outcome determinative.

State v. Wilkins, 163 Ohio App.3d 576 (9th Dist. 2005) (de novo standard for trial-court legal conclusions)
State v. Rossiter, 2004-Ohio-4727 (9th Dist. 2004) (standard of review for postconviction DNA testing decisions)
State v. Russell, 127 Ohio App.3d 414 (9th Dist. 1998) (context for reconsideration of postconviction relief)
State v. Perez, 2007-Ohio-2897 (9th Dist. 2007) (procedural framework for postconviction DNA testing)