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State v. Martin
2014 Ohio 4447
Ohio Ct. App.
2014
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Background

  • Appellant Iramac S. Martin was convicted after a jury trial of aggravated robbery (R.C. 2911.01) and robbery (R.C. 2911.02).
  • Indictment charged aggravated robbery and two counts of robbery; Count 3 was dismissed before trial.
  • Evidence centered on a September 27–28, 2013 robbery of James Taylor in downtown Columbus, including description and identification of appellant.
  • Taylor testified he was robbed at gunpoint or by a black metallic object; a knife was later recovered by police in a recycling bin nearby.
  • Police recovered $67 from appellant; victim identified appellant at scene and in trial; trial court denied Crim.R. 29 motions; jury convicted and the court merged counts and sentenced appellant.
  • Appellant appeals the Crim.R. 29 judgment of acquittal denial, arguing insufficiency or manifest weight of the evidence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the evidence was sufficient to convict for aggravated robbery and robbery. Martin Martin contends insufficient/weightful evidence Convictions supported; not insufficient or weighty error

Key Cases Cited

  • State v. Carter, 2006-Ohio-2823 (8th Dist. 2006) (standard of review for Crim.R. 29 sufficiency)
  • State v. Tenace, 109 Ohio St.3d 255 (Ohio Supreme Court 2006) (sufficiency standard aligns with Jenks; CV review)
  • Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review (jury verdict sustained if any rational trier could convict))
  • State v. Vasquez, 2014-Ohio-224 (10th Dist. 2014) (manifest weight review requires weighing entire record; not substitute weighing by appellate court)
  • State v. Newbern, 2004-Ohio-3694 (10th Dist. 2004) (recovery of weapon or money not required to sustain conviction)
Read the full case

Case Details

Case Name: State v. Martin
Court Name: Ohio Court of Appeals
Date Published: Oct 7, 2014
Citation: 2014 Ohio 4447
Docket Number: 14AP-189
Court Abbreviation: Ohio Ct. App.