State v. Lester
2017 Ohio 6972
| Ohio Ct. App. | 2017Background
- Defendant Nyles J. Lester was convicted in Franklin County Court of Common Pleas of rape and kidnapping for having sexual intercourse with a heavily intoxicated female college student.
- The victim was highly intoxicated, remembered Lester being "on her and in her," and reported the incident to friends and police immediately.
- Vaginal swabs collected after the incident contained male DNA; testing produced a partial Y-chromosome profile that did not exclude Lester but did not uniquely identify him.
- No semen or conclusive autosomal DNA linking Lester to the victim was recovered; the victim did not recall details such as condom use or ejaculation.
- Lester appealed arguing (1) insufficient and manifest-weight problems because of lack of DNA and victim intoxication, (2) due-process issues from admission of partial Y-chromosome evidence, and (3) Eighth Amendment challenge to lifetime registration tied to a conviction based on partial Y evidence.
- The trial court convicted and classified Lester as a Tier III sex offender; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency / manifest weight of evidence to support rape conviction | State: Victim’s prompt report, her testimony, and witnesses placing Lester at scene suffice | Lester: Victim intoxicated and lack of Lester’s DNA on victim undermines guilt | Affirmed — evidence and victim testimony were sufficient; verdict not against manifest weight |
| Admissibility / due process re: partial Y‑chromosome evidence | State: Partial Y evidence shows male contact and is proper corroborative evidence | Lester: Using partial Y profiles violates due process when they’re non-identifying | Affirmed — Y evidence permissible; it only showed male contact and did not decide the case alone |
| Eighth Amendment challenge to lifetime registration based on partial Y evidence | State: Registration is statutory consequence of conviction | Lester: Lifetime registration based on conviction partly supported by partial Y profile is cruel/unusual | Affirmed — classification required by statute after conviction; no error in imposition |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest-weight standards)
- State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for legal sufficiency of evidence following Jackson v. Virginia)
- Jackson v. Virginia, 443 U.S. 307 (1979) (legal sufficiency requires that a rational trier of fact could find guilt beyond a reasonable doubt)
- State v. Martin, 20 Ohio App.3d 172 (1983) (court of appeals as "thirteenth juror" when reviewing manifest-weight claims)
- Columbus v. Henry, 105 Ohio App.3d 545 (1995) (discussion of appellate review and manifest-weight standard)