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