State v. Mathis, 2019 Ohio 4887

On Feb. 26, 2015, a shooting outside Apartment 102 killed Tyrone Rodgers; security footage showed Terry Thomas and Kurtis Fields entering Mathis’s apartment seconds before the shooting.
Police interviewed Jasmine Mathis at the scene; she initially denied knowing the shooters or calling anyone, but detectives later learned she made phone calls around the time of the shooting.
Detective Borden asked Mathis to sign a written consent-to-search form for her cell phone; she signed and officers seized and downloaded the phone, which showed two deleted call entries near the time of the shooting.
Mathis moved to suppress the phone evidence and her statements arguing involuntary consent, illegal seizure, an unlawful pat-down, and lack of Miranda warnings; the trial court denied the motion.
At trial Mathis was acquitted of obstructing justice but convicted of tampering with evidence (deleting calls); she was sentenced to one year in prison.
On appeal, the Eighth District affirmed, holding consent to search was voluntary and the circumstantial evidence sufficed to prove knowledge of an imminent investigation (mens rea) for tampering.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mathis)	Held
Whether Mathis voluntarily consented to warrantless search of her phone	Consent was valid: Mathis signed a written form after being informed; no coercion shown	Consent was involuntary because police created a coercive environment and implied a warrant would be obtained	Court: Consent voluntary; totality of circumstances supports voluntariness and Detective's statement about a warrant was not coercive
Whether evidence was sufficient to prove tampering mens rea (knowledge an investigation was likely)	Circumstantial evidence (deleted calls timed to shooting, relationship with suspects, initial misstatements) permits inference she knew an investigation was likely	Insufficient proof she knew police would investigate when she deleted calls; no direct evidence of knowledge	Court: Evidence sufficient; rational juror could infer she knew an investigation was likely and deleted calls to impair evidence availability

Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (voluntariness of consent judged from totality of circumstances)
Katz v. United States, 389 U.S. 347 (1967) (warrant requirement and Fourth Amendment reasonableness)
Florida v. Jimeno, 500 U.S. 248 (1991) (scope of consent measured by objective reasonableness)
State v. Burnside, 100 Ohio St.3d 152 (2003) (appellate review standard for suppression findings)
State v. Straley, 139 Ohio St.3d 339 (2014) (elements of tampering with evidence and requirement of purpose)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency review standard: whether any rational trier could find guilt beyond reasonable doubt)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency from manifest weight review)