State v. Masters
2020 Ohio 864
Ohio Ct. App.2020Background
- In July 2018 Jodi and Ryan Nau staged a burglary to file a false insurance claim to pay Jodi’s cocaine debt.
- Jodi regularly used cocaine, had memory gaps, and owed appellant Todd Masters, her supplier; they communicated frequently about her financial problems.
- On July 4, vehicles, a trailer, dirt bikes, electronics, and firearms were taken; the two vehicles were later found burned.
- Cell records showed numerous calls/texts between Jodi and Masters around the incident; Jodi later admitted the burglary was staged, pleaded guilty to insurance fraud (intervention in lieu of conviction), and implicated Masters.
- Recorded conversations (one by detectives, one privately by Jodi) included Masters saying he knew who had the dirt bikes, he would "keep an eye out," and referencing being affected by an explosion and having scars.
- Masters was indicted for complicity to commit insurance fraud, convicted after a bench trial, and appealed challenging sufficiency and manifest weight of the evidence; the conviction was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence showed Masters participated in taking property used to support a false claim | Jodi's testimony, call/text logs, and taped conversations show Masters took part/ knew locations | No credible evidence he stole items; Jodi unreliable due to drug-induced memory loss | Court credited the evidence and found participation proved; conviction affirmed |
| Whether conviction required proof Masters actually submitted the insurance claim | Complicity law covers those who aided or facilitated the fraud; taking items with shared intent suffices | There is no evidence he was involved in filing the claim | Court held actual filing not required; aiding/theft with shared intent establishes complicity |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (defines Ohio's manifest-weight standard)
- State v. Johnson, 93 Ohio St.3d 240 (complicity requires supporting/assisting and shared criminal intent)
- State v. Martin, 20 Ohio App.3d 172 (reversal for manifest weight is for exceptional cases where evidence heavily opposes the conviction)
- State v. DeHass, 10 Ohio St.2d 230 (appellate review deferential to trial court credibility findings)