State v. Mansfield, 69 N.E.3d 767

On July 4, 2014, after an altercation at a Clark County campground, Erin Mansfield sat on Todd Griffith’s chest and choked him; Griffith later died at the scene.
Coroner concluded cause of death was asphyxia from choking and chest compression.
Mansfield was indicted on three counts of involuntary manslaughter (predicated on aggravated assault, assault knowingly causing physical harm, and assault recklessly causing serious physical harm) and one count of voluntary manslaughter.
Jury convicted Mansfield on all counts; offenses merged for sentencing and she received an 11-year prison term.
Before trial Mansfield filed an affidavit claiming indigency and requested state payment for an expert witness; the trial court summarily denied the motion because Mansfield had retained private counsel and held no hearing.
The appellate court found the summary denial an abuse of discretion, reversed and vacated the convictions and sentence, ordered a new trial, but reviewed sufficiency of the evidence claim and upheld sufficiency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether retaining private counsel alone precludes indigency for funding expert assistance	State: retained counsel indicates defendant can pay defense costs; denial proper	Mansfield: retention of counsel does not by itself defeat indigency for other expenses; she submitted affidavit showing inability to pay expert	Court: Retention of private counsel is not dispositive; trial court abused discretion by summarily denying motion without inquiry or hearing; reversal and remand for new trial
2. Whether evidence was sufficient to support convictions (knowingly/recklessly causing death; causation)	State: witness statements and coroner’s testimony support that Mansfield knowingly/recklessly choked Griffith and that her acts proximately and actually caused death	Mansfield: argued mental state and causation were not proved beyond reasonable doubt	Court: Evidence sufficient; witnesses’ statements and coroner’s findings permit reasonable juror to find mental state and causation beyond a reasonable doubt

Ake v. Oklahoma, 470 U.S. 68 (1985) (indigent defendant has due-process right to state-funded expert assistance in some circumstances)
State v. Mason, 82 Ohio St.3d 144 (1998) (standards for when state must provide funds for expert assistance)
State v. Tymcio, 42 Ohio St.2d 39 (1975) (trial court must inquire into claimed inability to obtain counsel; indigency can change over time)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency and manifest-weight review)