State v. Meadows, 2020 Ohio 802

Isaiah Meadows was indicted on multiple counts including rape, attempted rape, kidnapping, grand theft, weapons offenses, and related specifications; he initially pleaded guilty, that plea was vacated on appeal for Crim.R. 11 defects, and the case proceeded to trial on remand.
Victim (T.T.) testified she was sitting in her car when an unknown man brandished a gun, forced her to perform oral sex at gunpoint, told her to move over, then stole her car and drove off.
Police later chased and stopped the stolen vehicle; Meadows was arrested after crashing the car; a loaded firearm recovered from him had DNA consistent with T.T. and Meadows; T.T.’s DNA was found on Meadows’ penile swabs and his semen on T.T.’s shirt.
Meadows gave a recorded interview admitting he approached T.T.’s car, made her slide over, stole the car, and saying she was "in the wrong place at the wrong time;" he denied the sexual assault.
Jury found Meadows guilty of rape and most other counts; trial court imposed an aggregate sentence of life with parole eligibility after 29 years and stated at sentencing that costs were “stayed while incarcerated,” but the written journal entry imposing costs did not reflect that stay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court journalized its oral order staying payment of costs while incarcerated	State conceded the court did not journalize the stay and did not oppose remand for correction	Meadows argued the court orally stayed costs at sentencing but failed to reflect that in the journal entry	Court remanded for the trial court to issue a nunc pro tunc entry stating costs are stayed while Meadows is incarcerated; first assignment of error sustained
Whether the rape conviction was against the manifest weight of the evidence	State argued victim credible; physical and DNA evidence and Meadows’ admissions corroborate coercion	Meadows argued he never admitted forcing oral sex and the sexual act was consensual; victim not credible	Court affirmed conviction, finding no exceptional miscarriage of justice; second assignment of error overruled

State v. Miller, 940 N.E.2d 924 (Ohio 2010) (a court speaks through its journal entries; entries must reflect proceedings)
State ex rel. Worcester v. Donnellon, 551 N.E.2d 183 (Ohio 1990) (journal entries must be accurate reflections of proceedings)
State ex rel. Cruzado v. Zaleski, 856 N.E.2d 263 (Ohio 2006) (definition of clerical mistake amenable to correction)
State v. Brown, 737 N.E.2d 1057 (Ohio App. 2000) (clarifies clerical error concept)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court may correct clerical mistakes in sentencing entries via nunc pro tunc)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (standard for manifest-weight review)
Tibbs v. Florida, 457 U.S. 31 (U.S. 1982) (appellate court as "thirteenth juror" on weight of the evidence)
State v. Martin, 485 N.E.2d 717 (Ohio App. 1985) (new-trial standard when evidence weighs heavily against conviction)
State v. DeHass, 227 N.E.2d 212 (Ohio 1967) (deference to factfinder on witness credibility)