State v. Logan, 2024 Ohio 2360

Montez Logan was convicted in 2010 for aggravated murder, attempted murder, and weapons offenses from a shooting in Cleveland, Ohio, in which two people were killed and others injured.
Key evidence at trial included eyewitness testimony, particularly from Anton Weems, and the identification of Logan and his codefendant, Allen, as shooters; both defendants presented an alibi defense.
Logan’s conviction was affirmed on direct appeal; subsequent motions to reopen or overturn the conviction failed.
In 2023, over a decade after the trial, Logan moved for leave to file a motion for new trial, presenting "newly discovered evidence" including recantation affidavits from Weems and another witness (Perkins), and court records allegedly undermining another witness's credibility.
The trial court denied Logan’s motion without an evidentiary hearing, prompting this appeal; a dissent from one appellate judge would have granted a hearing.

Issue	Logan's Argument	State's Argument	Held
Was Logan unavoidably prevented from discovering the "new evidence"?	Logan asserts recantation affidavits and new court records were unattainable until recently.	State says Logan failed to show why this evidence was not discoverable earlier with due diligence.	No; court found no clear, convincing showing of unavoidable prevention.
Did affidavits and materials meet the standard for credibility and materiality under Calhoun?	Affidavits should be trusted and support a prima facie case for relief.	Affidavits are contradictory or not new; merely recant previous evidence.	No; affidavits merely contradicted earlier trial evidence, which is insufficient.
Do the materials constitute Brady material that was improperly withheld?	Garfield Heights records and Weems’s motivation for testifying were suppressed and exculpatory.	These are public records or not exculpatory; not suppressed by prosecution.	No Brady violation; materials were either public or not shown to be suppressed.
Did the trial court err by not providing factual findings or prioritizing judicial efficiency?	Failure to issue findings of fact or comment on standards was error.	No requirement for detailed findings; denial was appropriate.	No error; findings of fact are a "best practice" but not mandatory.

State v. Calhoun, 86 Ohio St.3d 279 (Ohio 1999) (establishes standards for considering credibility of affidavits in postconviction/new trial context)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose evidence favorable to the defense if material to guilt or punishment)
State v. Bethel, 2022-Ohio-783 (Ohio 2022) (interprets "unavoidably prevented" standard and application of Brady claims in untimely postconviction petitions)
State v. White, 2017-Ohio-6984 (Ohio Ct. App. 2017) (evidence contradicting trial testimony alone is insufficient for new trial)