State v. McFarland (Slip Opinion)
164 N.E.3d 316
Ohio2020Background
- Victim Robert Williams, a police informant, helped convict supplier Eddie “Mann” Brownlee; Brownlee’s girlfriend Sheila McFarland was arrested in a controlled buy and later released.
- Brownlee called from jail (recorded calls) accusing Williams of snitching and saying he would "get him"; Brownlee told Motley (the eventual shooter) to handle Williams; calls and texts discussed a gun described as Brownlee/McFarland’s.
- McFarland left voicemails accusing Williams and his girlfriend Korri Henderson of being snitches, socialized and sold drugs with Motley while Brownlee was jailed, and was present in hotel(s) linked to planning and post-event meetings according to prosecution evidence.
- On Nov. 14, 2015 Motley (with accomplices) ambushed and shot Williams in his apartment hallway; Motley later reported to Brownlee “It’s done.” Motley pleaded guilty and testified at McFarland’s trial with mixed statements about her role.
- McFarland was tried, convicted on multiple counts (including aggravated murder, conspiracy, aggravated burglary, kidnapping), sentenced to life without parole on the aggravated-murder count, and appealed on sufficiency-of-the-evidence grounds; the Ohio Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (McFarland) | Held |
|---|---|---|---|
| Sufficiency for aggravated murder (R.C. 2903.01(A)) | McFarland aided/abeted and solicited the murder: recorded jail calls, texts about the gun, presence at planning/post meetings, drug proceeds used to pay shooter, voicemails threatening informants show prior calculation and design | Evidence is circumstantial and insufficient; Motley (triggerman) testified McFarland had no role; mere anger/association insufficient | Affirmed — viewing evidence in the light most favorable to the prosecution, a rational juror could find McFarland complicit in murder (aiding/abetting, solicitation) with prior calculation and design |
| Sufficiency for conspiracy to commit murder (R.C. 2923.01) | Conspiracy established by agreement and substantial overt acts: soliciting Motley, assisting/procuring the firearm, and threatening calls/voicemails | No overt acts by McFarland to promote or facilitate murder; Motley’s proffer/trial testimony largely exculpatory | Affirmed — state proved agreement + substantial overt acts (providing gun, threats/voicemails, solicitation) |
| Sufficiency for aggravated burglary (R.C. 2911.11(A)(1)) | McFarland was complicit: assailants used stealth (masks, tape over peepholes), entered occupied structure to inflict harm; she aided the scheme | She was not present in building; no direct participation in entry or assault | Affirmed — rational juror could find complicity through presence, conduct, and assistance to perpetrators |
| Sufficiency for kidnapping (R.C. 2905.01(A)(3)) | Video and testimony show assailants confronted and restrained Williams to inflict serious harm; McFarland was complicit in the plan | No evidence McFarland participated in the restraint or intended harm | Affirmed — evidence sufficient for a rational juror to find McFarland complicit in kidnapping |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes constitutional sufficiency-of-the-evidence standard)
- Tibbs v. Florida, 457 U.S. 31 (discusses effect of conviction based on insufficient evidence)
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio discussion of sufficiency and due process principles)
- State v. Jenks, 61 Ohio St.3d 259 (articulates Ohio standard for appellate sufficiency review)
- State v. Johnson, 93 Ohio St.3d 240 (defines aiding and abetting and participation in criminal intent)
- State v. Childs, 88 Ohio St.3d 194 (conspiracy indictment must allege a substantial overt act)
- State v. Antill, 176 Ohio St. 61 (jury may accept or reject witness testimony and weigh credibility)