State v. McCrone, 2019 Ohio 337

Defendant Allen McCrone was tried in Warren C.P. for multiple January–February 2017 residential burglaries/attempted burglaries in Mason, Ohio, and possession of criminal tools; convictions affirmed on appeal.
Law‑enforcement obtained two warrants: (1) cellphone location records from Sprint and (2) a GPS tracker clandestinely placed on McCrone’s vehicle; data showed presence near multiple crime scenes in Long Cove.
At Khan’s home, exterior camera footage showed a slender person enter an unlocked vehicle, open the garage, and enter the house; latent fingerprints from that vehicle were matched to McCrone by a county examiner.
McCrone was later found near his parked vehicle wearing clothing matching witnesses’ descriptions (blue jeans, black hooded sweatshirt) with gloves, a flashlight, muddy shoes, and a duffel bag containing many stolen gift cards traced to burglary victims.
Defense challenged the authentication/interpretation of Sprint records and the qualifications/reliability of the latent‑print examiner; court overruled and found the examiner qualified and Sprint records admissible (defense had stipulated to authenticity at trial).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to identify McCrone for Rentfrow burglary	Sprint records and circumstantial similarity to other burglaries place McCrone nearby; GPS and pattern evidence support ID	Sprint evidence inadmissible hearsay and insufficient to prove identity	Affirmed — Sprint records were arguably business records; defendant had stipulated authenticity; other circumstantial evidence supported conviction
Qualification/reliability of latent‑print examiner for Khan burglary	Examiner qualified by training, experience; method explained and verified by second examiner	Examiner lacked credentials and trial experience; opinion unreliable	Affirmed — trial court did not abuse discretion admitting expert testimony; challenges went to weight, not admissibility
Sufficiency for attempted burglaries (O’Brien & Mullins) — substantial step	Presence on back patio/porch at night, similar clothing, nearby burglaries, and behavior (attempting door handle) are strongly corroborative of criminal purpose	Photo or single appearance insufficient to show substantial step toward burglary	Affirmed — facts constituted substantial steps corroborating intent to commit burglary
Possession of criminal tools dependent on burglary convictions	N/A — State argues tools used in burglaries and found on defendant	If underlying burglaries unsupported then tools charge fails	Affirmed — because burglary convictions upheld, tools conviction stands

State v. Jenks, 61 Ohio St.3d 259 (defining sufficiency review standard for criminal convictions)
State v. Barnes, 94 Ohio St.3d 21 (plain‑error standard in criminal cases)
State v. Biros, 78 Ohio St.3d 426 (plain‑error requires showing outcome would clearly have been otherwise)
State v. Mack, 73 Ohio St.3d 502 (standard for trial court’s admission of expert testimony)
State v. Group, 98 Ohio St.3d 248 (definition of attempt and substantial‑step requirement)
State v. Maupin, 42 Ohio St.2d 473 (deference to trial court on expert qualification)