State v. Knauff, 2014 Ohio 308

Defendant Travis Knauff was convicted by a jury of raping his then-five‑year‑old daughter and sentenced to life without parole; conviction affirmed on direct appeal.
Physical evidence: insulation removed from a hole in defendant’s bedroom floor tested positive for a mixture of semen and amylase; major DNA profile matched Knauff, minor profile unidentified.
Child victim gave video-recorded forensic interview and in‑camera testimony describing repeated sexual abuse and stating she spat the defendant’s ejaculated "pee" into the hole in the floor.
At trial Knauff testified he masturbated into the hole after seeing his fiancée shower; fiancée (Jerrylyn Younts) testified defendant was never alone with the child.
Postconviction petition alleged ineffective assistance: trial counsel failed to elicit Younts’s affidavit that she performed oral sex on Knauff and spit his ejaculate into the floor hole (an alternative source for the semen), and the court dismissed the petition without an evidentiary hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to elicit fiancée’s testimony explaining semen on insulation	Knauff: counsel was ineffective for not calling/eliciting Younts’s testimony that she received Knauff’s ejaculate in her mouth and spat it into the hole	State: counsel reasonably chose not to present a conflicting alternate explanation that would undercut Knauff’s credibility and might corroborate sexual behavior; counsel already offered an alternate (Knauff’s masturbation)	Court: No abuse of discretion — counsel’s omission was a reasonable tactical decision and petition failed to allege operative facts showing deficient performance or prejudice
Denial of evidentiary hearing on postconviction petition	Knauff: petition and Younts affidavit established substantive grounds warranting a hearing	State: record and affidavits did not demonstrate operative facts meeting R.C. 2953.21(C) standard	Court: Denial affirmed — statutory standard for hearing not met; dismissal without hearing was not unreasonable

Evitts v. Lucey, 469 U.S. 387 (right to effective assistance of counsel at appellate level, general right to counsel principles)
Strickland v. Washington, 466 U.S. 668 (ineffective‑assistance standard: deficient performance and prejudice)
State v. Calhoun, 86 Ohio St.3d 279 (postconviction relief is collateral, not a matter of right; hearing only where operative facts alleged)
State v. Gondor, 112 Ohio St.3d 377 (deference to trial court’s postconviction factual findings; standard of review)
State v. Bradley, 42 Ohio St.3d 136 (failure to satisfy either Strickland prong is fatal)
State v. Short, 129 Ohio St.3d 360 (application of ineffective‑assistance test)