State v. Ladson, 2016 Ohio 7781

In January 2015 a 9 mm handgun was reported stolen after being left in a car; Marcus Ladson was the only other person in that car that night.
Two months later the victim ran to her mother saying Ladson returned and fired shots through the apartment window.
Police found Ladson in the victim’s bedroom and recovered the stolen handgun in a nearby clothes hamper; a spent casing and bullet damage matched the gun, and gunshot residue was on both Ladson and the gun.
At trial the victim recanted, giving testimony inconsistent with her prior excited statements to her mother and the police; there was also a minor police-report mistake about the gun’s magazine.
A jury convicted Ladson of discharging a firearm into habitation (with firearm specifications), having a weapon while under disability, receiving stolen property, drug possession, and aggravated menacing; the trial court imposed consecutive maximum terms totalling 16.5 years.
On appeal Ladson challenged sufficiency/manifest weight of the evidence, the use of the victim’s written statement during deliberations, and the imposition of consecutive sentences.

Issue	State's Argument	Ladson's Argument	Held
Sufficiency of evidence for convictions	Evidence (weapon matched casing, GSR on gun and Ladson, witness accounts) proved elements beyond a reasonable doubt	Evidence insufficient — victim recanted and officer made report error; other evidence untrustworthy	Affirmed: evidence sufficient to support convictions
Manifest weight of evidence	Credibility resolved by jury; other witnesses corroborated state’s case	Conviction against manifest weight due to victim’s recantation and officer mistake	Affirmed: not an exceptional case; weight favors conviction
Use of victim’s written statement in deliberations	Statement was not introduced or sent to jury	Trial court erred by permitting written statement to be used in deliberations	Overruled: no record support of error and appellant failed to develop argument per App.R.16(A)(7)
Consecutive sentences (challenge under Kalish/Marcum)	Trial court made required R.C. 2929.14(C)(4) findings; record supports consecutive terms	Trial court abused discretion by ordering consecutive maximum sentences and failed to properly apply sentencing factors	Affirmed: appellate review limited by Marcum; findings supported and consecutive terms not contrary to law

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review)
State v. Marcum, 146 Ohio St.3d 516 (2016) (limits appellate review of final sentences under R.C. 2953.08)
State v. Kalish, 120 Ohio St.3d 23 (2008) (appellate review framework for felony sentencing challenges)