State v. Lanier
2010 Ohio 6382
Ohio Ct. App.2010Background
- Lanier was convicted by the Mahoning County Common Pleas Court of rape, complicity to murder, complicity to kidnapping, and complicity to aggravated robbery; aggregate sentence 55 years to life.
- Six-count indictment accused Lanier of crimes against Sierra Slaton, with firearm specifications on several counts.
- Y-STR DNA testing on Slaton’s vaginal swab and reference samples from Lanier and Jackson yielded exclusion for Jackson and non-exclusion for Lanier; partial eight-locus profile.
- Slaton’s body was found at McKelvey Lake; semen was detected on her vaginal swab; the autopsy noted multiple gunshot wounds and submersion in water.
- Antwain Blackmon testified for the state as a key witness; defense challenged credibility and the admissibility of DNA evidence; trial included detective interview and Miranda waiver.
- On appeal, Lanier challenged Doyle post-arrest silence comments, Crawford/Melendez-Diaz confrontation issues, manifest weight, sufficiency, and cumulative error; the court affirmed all convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Doyle post-arrest silence during closing arguments | Lanier asserts Doyle violation from comments on post-arrest silence | State allegedly emphasized silence to imply guilt | No Doyle violation; any error is harmless if present. |
| Confrontation under Melendez-Diaz for DNA testing | Lanier argues Johnson’s testimony violated confrontation by not being the analyst | Johnson performed the Y-STR testing and testified as such | No confrontation violation; Johnson’s testimony established she performed the testing. |
| Manifest weight of the evidence | Blackmon’s credibility and Y-STR admissibility render verdicts against weight | Jury could reasonably credit Blackmon and other evidence | Convictions not against the manifest weight of the evidence. |
| Sufficiency of the evidence for rape conviction | Y-STR results and other evidence insufficient to prove rape | The evidence, including circumstantial proof, supports rape | Sufficient evidence supports rape conviction. |
| Cumulative error | Multiple asserted errors cumulatively warrant reversal | Errors are harmless individually or non-existent | No cumulative error; convictions affirmed. |
Key Cases Cited
- Doyle v. Ohio, 426 U.S. 610 (U.S. 1976) (prohibition on commenting on post-arrest silence during trial)
- State v. Williams, 64 Ohio App.2d 271 (Ohio App. 1979) (disfavor of comment on post-arrest silence)
- Melendez-Diaz v. Massachusetts, 557 U.S. 304 (U.S. 2009) (confrontation right applies to test results by analysts)
- Chaney v. State, 2010-Ohio-1312 (7th Dist.) (state’s references to defendant’s lack of testing not Doyle violation)
- State v. Davis, 116 Ohio St.3d 404 (Ohio 2008) (references to defendant’s failure to offer evidence not misconduct)
- State v. Collins, 89 Ohio St.3d 524 (Ohio 2007) (allowing reference to available witness testimony)
- State v. Williams, 23 Ohio St.3d 16 (Ohio 1986) (likelihood of acquittal based on evidentiary weight and credibility)