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State v. Locke
2018 Ohio 27
| Ohio Ct. App. | 2018
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Background

  • Jonah A. Locke was indicted by an Ashland County grand jury on three counts of public indecency (two fifth-degree felonies, one first-degree misdemeanor) for incidents on April 25 and April 29, 2016.
  • Multiple witnesses (including a 10‑year‑old child, two young children’s great‑grandmother, neighbors, and passersby) testified that a shirtless or hooded man pulled down his pants and exposed or masturbated in view of children and adults; several witnesses identified Locke from photos and at trial.
  • Some identification issues existed: initial police descriptions differed, some witnesses failed to pick a suspect from early lineups, one witness admitted not wearing glasses when observing the act, and photographic lineups were administered on different dates.
  • A jury convicted Locke on all counts after a two‑day trial; sentence included one year imprisonment on Count 1, 90 days concurrent on Count 3, and community control on the remaining count.
  • On appeal Locke argued his convictions were against the manifest weight of the evidence, challenging witness credibility and identification reliability.

Issues

Issue State's Argument Locke's Argument Held
Whether convictions were against the manifest weight of the evidence Witness identifications and trial testimony supported convictions; inconsistencies were for the jury to resolve Witness descriptions conflicted with early reports; identification procedures and witness reliability (e.g., no glasses) undermine the verdict Affirmed: the jury did not lose its way; weight and credibility were for the jury to decide

Key Cases Cited

  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for reversing a conviction as against the manifest weight of the evidence)
  • State v. Smith, 80 Ohio St.3d 89 (1997) (clarifying limits on Thompkins on other grounds)
  • State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility of witnesses is for the trier of fact)
  • Davis v. Flickinger, 77 Ohio St.3d 415 (1997) (appellate courts defer to jury’s view of witness demeanor and credibility)
  • State v. Antill, 176 Ohio St. 61 (1964) (jury may accept portions of testimony and reject other parts)
Read the full case

Case Details

Case Name: State v. Locke
Court Name: Ohio Court of Appeals
Date Published: Jan 2, 2018
Citation: 2018 Ohio 27
Docket Number: 17-COA-019
Court Abbreviation: Ohio Ct. App.