State v. Letner, 2023 Ohio 610

Letner was indicted on multiple counts arising from his relationship with Jane Doe and activities she described as prostitution; he was convicted only of promoting prostitution (R.C. 2907.22(A)(2)).
Doe testified Letner supervised her prostitution: writing/posting ads, responding to calls/texts, setting prices/appointments, and handling money.
Kevin North corroborated seeing advertisements and Letner acting as the contact for appointments.
Police responded to a welfare check at the hotel; multiple cell phones were seized but not fully forensically reviewed at trial.
Before voir dire, Letner objected to appearing in an orange jail uniform; the court allowed him to proceed in jail clothes (no restraints) and gave a curative presumption-of-innocence instruction.
On appeal Letner raised (1) that being forced to wear jail clothes violated due process/presumption of innocence, and (2) that his promoting-prostitution conviction was against the manifest weight of the evidence.

Issue	State's Argument	Letner's Argument	Held
1. Whether permitting Letner to try his case in jail clothing (without restraints) violated due process/presumption of innocence	No compulsion by the State; defendant had months to obtain civilian clothes; curative instruction cured any prejudice	Appearance in identifiable jail clothing was inherently prejudicial and compelled, violating Estelle	Court held Letner was not compelled to wear jail clothes, had opportunity to secure civilian clothing, received curative instruction, and suffered no prejudice — claim denied
2. Whether conviction for promoting prostitution was against the manifest weight of the evidence	Evidence (Doe + North) showed Letner supervised/managed Doe’s prostitution (ads, communications, money)	State’s case relied on Doe’s testimony and was insufficient/against the weight of evidence	Court held the evidence (corroborated by North) was persuasive; conviction was not against the manifest weight of the evidence

Estelle v. Williams, 425 U.S. 501 (1976) (holding a defendant cannot be compelled to stand trial in identifiable jail clothing)
Holbrook v. Flynn, 475 U.S. 560 (1986) (courtroom displays and distinctive attire can affect juror judgment)
Tibbs v. Florida, 457 U.S. 31 (1982) (due-process considerations for verdicts and review standards)
Thompkins v. Ohio, 78 Ohio St.3d 380 (1997) (Ohio standard for manifest-weight review)
State v. Wilson, 113 Ohio St.3d 382 (2007) (discussion of the manifest-weight standard and appellate review)
State v. Loza, 71 Ohio St.3d 61 (1994) (presumption that jurors follow curative jury instructions)
State v. Fears, 86 Ohio St.3d 329 (1999) (reinforcing that jurors are presumed to follow instructions)