State v. Liles, 2014 Ohio 259

Liles was indicted on felonious assault with a deadly weapon and a firearm specification in 2012; amended indictment added Counts 1–3: felonious assault, reckless discharge of a firearm, and having a weapon while under disability.
Plea entered: not guilty to amended indictment; trial was held in January 2013 with a jury verdict of guilty on all three counts.
Trial court merged Counts One and Two as allied offenses and sentenced as a single count, while Count Three was not merged; the State elected Count One for sentencing.
Sentence: eight years on Count One and 24 months on Count Three, consecutive, for an aggregate term of ten years.
Liles appealed February 2013, raising manifest weight of the evidence and ineffective-assistance-of-counsel challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the felonious assault and weapon-under-disability conviction against the manifest weight?	Liles contends the verdict rested on biased, inconsistent witnesses with no physical evidence.	Liles argues the State failed to prove guilt beyond a reasonable doubt due to lack of physical evidence and witness unreliability.	Not against the weight; evidence supported verdicts.
Did trial counsel render ineffective assistance by not objecting to certain testimony?	Liles claims objections to prior-incarceration testimony and Detective Miller’s redirect testimony were necessary.	State argues admissibility and opening the door to related testimony; no ineffective assistance.	No reversible error; counsel's performance not deficient or prejudicial.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest weight standard; credibility scrutiny)
State v. Martin, 20 Ohio App.3d 172 (1983) (weight-of-the-evidence standard; appellate review)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight determined by trier of fact)
State v. Johnson, 128 Ohio St.3d 153 (2010) (merger of allied offenses; 2941.25)
State v. Kole, 92 Ohio St.3d 303 (2001) (ineffective-assistance framework)
State v. Sallie, 81 Ohio St.3d 673 (1998) (standard of appellate review for counsel performance)
State v. Campbell, 69 Ohio St.3d 38 (1994) (objection strategy and trial strategy considerations)
State v. Lytle, 48 Ohio St.2d 391 (1976) (trial tactics and reasonable professional assistance)
Lundgren v. Mitchell, 440 F.3d 754 (6th Cir.2006) (objecting to objections and strategic decisions)
State v. Holloway, 38 Ohio St.3d 239 (1988) (strong-presumption of effective assistance; strategic decisions)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective assistance standard)
Bradley, 42 Ohio St.3d 136 (1989) (prejudice component of ineffective assistance)
Johnson, 112 Ohio St.3d 210 (2006) (prejudice from failure to object; general principle)
Rode v. State, State v. Rode (Not provided) (trial testimony and corroboration issues (cited in opinion))