State v. Inman
2013 Ohio 3351
Ohio Ct. App.2013Background
- William A. Inman II was tried and convicted of two counts of aggravated murder, kidnapping, tampering with evidence, and gross abuse of a corpse for the kidnapping and killing of his wife; he received consecutive life terms.
- Multiple eyewitnesses described a white, old-style Crown Victoria (police-cruiser appearance) at the kidnapping scene and later near where the body was dumped; technological evidence (cell-site records and a GPS unit) placed Inman in Logan, Ohio the evening of the disappearance.
- John Anthony Matheny gave a March 24, 2011 police statement noting he saw a white Crown Victoria with a blonde driver and two male occupants but did not identify Inman in that written statement.
- During trial preparation Matheny told prosecutors he could identify Inman as one of the male passengers; at trial Matheny identified Inman, surprising defense counsel who moved for a mistrial. The court denied the mistrial and granted a short continuance for preparation.
- After trial defense learned Matheny had a prior felony conviction (gross sexual imposition) that was not disclosed pretrial; defense moved for a new trial alleging prosecutorial nondisclosure and impeachment harm. The trial court denied the motion and the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court erred in denying mistrial for State’s alleged failure to disclose pretrial ID | State: no discovery violation — produced police statement and witness list; prosecutor’s notes/witness prep not required to be disclosed | Inman: ID at trial was surprising, prejudicial, and required pretrial disclosure under Crim.R.16/Brady | No abuse of discretion; no Crim.R.16 or Brady violation; continuance cured surprise |
| Whether nondisclosure of Matheny’s prior felony required new trial | State: nondisclosure was not material; overwhelming independent evidence placed Inman in Logan | Inman: failure to disclose prior conviction prevented impeachment under Evid.R.609 and was prosecutorial misconduct warranting new trial | Denial of new trial affirmed; conviction not undermined — nondisclosure not material to outcome |
| Whether cumulative error deprived defendant of a fair trial | State: no multiple errors occurred; individual rulings were proper | Inman: combined effect of discovery and impeachment failures warrants reversal | No cumulative error because appellate court found no individual errors |
| Whether Crim.R.16(B)(7) required disclosure of witness statements from prosecutor notes/witness prep | State: written/recorded statements only include signed, adopted, or substantially verbatim documents; prosecutor notes/work product excluded | Inman: prosecution should have disclosed that Matheny could identify defendant | Prosecutor’s notes/witness-prep statements are work product and not discoverable; Crim.R.16 not violated |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (suppression of evidence favorable to accused violates due process)
- Kyles v. Whitley, 514 U.S. 419 (materiality assessed by reasonable probability that outcome would differ)
- United States v. Bagley, 473 U.S. 667 (favorable suppressed evidence is material if it undermines confidence in outcome)
- United States v. Agurs, 427 U.S. 97 (standard for impeachment evidence and materiality)
- State v. LaMar, 95 Ohio St.3d 181 (Ohio application of Brady materiality standard)
- State v. Jackson, 107 Ohio St.3d 53 (Crim.R.16 violation analysis factors)
- State v. Adams, 62 Ohio St.2d 151 (abuse of discretion standard explained)
- State v. Johnston, 39 Ohio St.3d 48 (withholding prosecution evidence: due process/new-trial framework)
- State v. Garner, 74 Ohio St.3d 49 (doctrine of cumulative error)