State v. Matthews
2017 Ohio 214
Ohio Ct. App.2017Background
- Ronald Matthews Sr. was indicted for one count of domestic violence for an incident on June 23, 2013, in which his wife testified he grabbed her hair, threw her to the floor, and kicked and struck her; their 12‑year‑old son and the responding officer corroborated the assault.
- The indictment charged a third‑degree felony under R.C. 2919.25 based on alleged prior domestic violence convictions (two prior convictions would raise the offense to a third‑degree felony under R.C. 2919.25(D)(4)).
- Matthews conceded a 1996 domestic‑violence conviction but denied recollection of a 1982 Tiffin Municipal Court conviction; the State introduced court records and testimony (records clerks and the 1982 victim) to establish the 1982 conviction.
- Matthews filed a motion in limine to exclude evidence and testimony about the prior convictions; the trial court denied the motion and permitted limited testimony about the 1982 and 1996 incidents and records.
- A jury convicted Matthews; he was sentenced to two years’ imprisonment and appealed, raising three assignments: (1) erroneous admission of prior‑conviction evidence, (2) insufficiency/manifest weight of the evidence (including proof of priors), and (3) cumulative error depriving a fair trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of prior‑conviction evidence (motion in limine) | State: proof of two prior convictions was necessary to support the felony enhancement and could be proven by records and limited testimony. | Matthews: testimony by his ex‑wives and records about prior convictions was prejudicial, amounted to "parading" ex‑wives, and should have been excluded. | Court: trial court did not abuse discretion; testimony and records were limited and relevant to establish prior convictions. |
| Sufficiency / Manifest weight of evidence (guilt and priors) | State: victim, son, and officer testimony plus documentary and testimonial proof of 1982 and 1996 convictions sustain the conviction and enhancement. | Matthews: evidence of priors was unreliable; overall evidence was insufficient and verdict against manifest weight. | Court: evidence was sufficient and weight of the evidence supported conviction and proof of prior convictions. |
| Cumulative error | State: no cumulative errors to aggregate; each ruling was proper. | Matthews: multiple errors together deprived him of a fair trial. | Court: no individual errors found, so no cumulative prejudice; conviction affirmed. |
Key Cases Cited
- Blakemore v. Blakemore, 5 Ohio St.3d 217, 450 N.E.2d 1140 (Ohio 1983) (standard for abuse of discretion review)
- State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (Ohio 1991) (sufficiency standard: evidence viewed in light most favorable to prosecution)
- State v. Hunter, 131 Ohio St.3d 67, 960 N.E.2d 955 (Ohio 2011) (cumulative‑error doctrine and reversal standard)