State v. Lane, 2017 Ohio 8050

Appellant James E. Lane (18 at the time) was indicted for rape under R.C. 2907.02(A)(1)(b) based on sexual activity with B.M.A., who was 12.
At trial a detective testified, over defense objection, that Lane had admitted at age 16 to digitally penetrating an 11-year-old girl; the State offered this as "other acts" evidence.
The jury convicted Lane of rape; the trial court sentenced him to 10 years to life imprisonment.
On appeal Lane contended (1) the trial court abused its discretion by admitting the prior juvenile-adjudication conduct under Evid.R. 404(B) and (2) his conviction was against the manifest weight of the evidence.
The appellate court reviewed the admissibility under an abuse-of-discretion standard and the weight challenge under the manifest-weight standard (Otten/Thompkins framework).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of other-acts evidence (prior juvenile sexual conduct)	State: evidence was admissible under Evid.R. 404(B) for legitimate purposes (e.g., intent/plan) and not unduly prejudicial	Lane: prior juvenile conduct was irrelevant to identity, intent, motive, opportunity, plan, or scheme and thus inadmissible; juvenile adjudications cannot be used for impeachment	Court: admission was within trial court’s discretion; other-acts may be used for purposes beyond identity (citing Williams); defendant failed to show Williams three-step error and record gap presumes regularity — assignment overruled
Manifest weight of the evidence	State: jury reasonably credited victim and corroborating evidence	Lane: testimony lacked forensic corroboration; alleged coercive police interview; inconsistencies about residence and witnesses make conviction unreliable	Court: jury was entitled to weigh credibility; no contradictions in victim’s statements shown; jury did not lose its way — assignment overruled

State v. Morris, 132 Ohio St.3d 337 (Ohio 2012) (Evid.R. 404(B) rulings reviewed for abuse of discretion)
State v. Williams, 134 Ohio St.3d 521 (Ohio 2012) (three-step test for admitting other-acts evidence)
State v. Schaim, 65 Ohio St.3d 51 (Ohio 1992) (other-acts may prove identity or scheme)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for manifest-weight review)
State v. Otten, 33 Ohio App.3d 339 (9th Dist. 1986) (procedural guide for manifest-weight analysis)
Prince v. Jordan, (unreported in text) omitted (not listed due to lack of official reporter citation)
DeHass v. State, 10 Ohio St.2d 230 (Ohio 1967) (credibility and weight of evidence are for the trier of fact)