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State v. Keller
2019 Ohio 1397
Ohio Ct. App.
2019
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Background

  • In Feb. 2018 appellant Rondale E. Keller approached a woman as she opened her driver-side car door, pushed/pinned her to the vehicle frame, swept her away from the door, and she fell to the ground.
  • While the victim was falling, Keller entered the running vehicle, took the keys, and drove off; the victim called 911 and sustained soreness and a minor abrasion to her elbow.
  • Police located the vehicle a few blocks away, used a dog to track to a house, obtained consent to enter, and found Keller in an upstairs bedroom.
  • Officers recovered the victim’s car keys concealed in an eyeglass case in the same bedroom; the victim identified Keller at the house and he was arrested.
  • Keller was indicted for robbery (R.C. 2911.02(A)(2)), convicted by a jury, and sentenced to five years’ imprisonment.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether conviction for robbery is against manifest weight of the evidence State: Victim and other witnesses credibly testified Keller pushed the victim, causing her fall and injury during the theft Keller: He found the car unlocked and running, didn’t touch the victim, and was intoxicated; thus no physical harm was inflicted during the theft Court: Affirmed — weight of the evidence supports robbery conviction; jury reasonably credited prosecution witnesses

Key Cases Cited

  • State v. Wilks, 154 Ohio St. 3d 359 (2018) (articulates standard for manifest-weight review and appellate deference to jury credibility determinations)
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Case Details

Case Name: State v. Keller
Court Name: Ohio Court of Appeals
Date Published: Apr 15, 2019
Citation: 2019 Ohio 1397
Docket Number: CA2018-07-137
Court Abbreviation: Ohio Ct. App.