State v. Jones, 135 Ohio St. 3d 10

Jones was charged with aggravated murder, murder, and two counts of rape for the death and sexual assault of Susan Yates; verdicts led to a death sentence.
Autopsy showed death by asphyxia due to strangulation with extensive genital injuries and evidence of sexual contact.
DNA evidence linked Jones to semen on vaginal swabs and skirt stains; a cross matching the cemetery scene was found.
Jones had a prior 1990 conviction for two counts of attempted rape, with trial testimony from a then-16-year-old victim about choking and attempted rape.
During trial, the state used a life-sized demonstrative doll to reenact Jones’s claimed conduct; the defense objected but the court allowed it.
The trial court admitted excited utterances from Jones’s wife Delores and later determined some statements were testimonial, implicating the Confrontation Clause; this led to mixed harmlessness analysis in the penalty phase.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Demonstrative doll admissibility and impact	Jones argues the doll was prejudicial and improper	State contends demonstrative aid was relevant to credibility	Demonstrative admissibility affirmed; relevant and not unfairly prejudicial
Spousal privilege and Confrontation Clause	Delores’s statements violated spousal privilege and were testimonial	Privilege and testimonial nature should be narrowly construed	Delores unavailable; Morrison's testimony testimonial and error; Jeffries akin to non-testimonial; some error harmless beyond a reasonable doubt
Opposing-acts testimony (TJ)	TJ's 1990 rape testimony admissible to show absence of accident and identity	Testimony unduly remote and prejudicial	Testimony admissible for identity and absence of accident; limited prejudicial impact mitigated by curative instructions
Penalty-phase prosecutorial conduct	Prosecutor engaged in misconduct during penalty phase cross-examination/opening	Opening statements and cross-examination within discretion	No reversible error; prosecutorial conduct not shown to alter outcome

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause; testimonial statements require unavailability unless prior cross-examination)
Davis v. Washington, 547 U.S. 813 (U.S. 2006) (Primary-purpose test for whether statements are testimonial in emergent contexts)
Hammon v. Indiana, 547 U.S. 813 (U.S. 2006) (Testimonial statements in domestic-violence context; ongoing emergency assessment)
State v. Landrum, 53 Ohio St.3d 107 (Ohio 1990) (Demonstrative evidence; impeachment value)