State v. Minton
2016 Ohio 5427
| Ohio Ct. App. | 2016Background
- Kelly Minton (defendant), the victim’s adopted uncle, was tried by jury and convicted of three counts of rape (one with a life specification); a fourth count was dismissed on Crim.R. 29. He was sentenced to life plus 16 years and classified Tier III sex offender.
- Allegations: sexual assaults occurred in 2007 (victim age 12), February 2008 (conception period; victim 13), and August 2008 (victim ~6 months pregnant). DNA testing showed a 99.9999% probability that Minton is the biological father of the victim’s child.
- Defense theory: consent as to the February 2008 encounter (Minton admitted intercourse that date) and attack on victim credibility through prior sexual history, alleged statements naming other fathers, and alleged prior false accusations.
- Trial rulings at issue: exclusion of certain in‑camera proffers and cross‑examination under Ohio’s rape‑shield statute (R.C. 2907.02(D)/(E)); admission of a notarized school calendar; limits on the defendant’s form of testimony; alleged prosecutorial misconduct; sufficiency/manifest weight challenges; and claimed judicial bias/recusal.
- Appellate outcome: the Fourth District affirmed on all counts (or dismissed the recusal claim for lack of appellate jurisdiction), finding no abuse of discretion, no constitutional violation, sufficient evidence of force, and no reversible prosecutorial misconduct.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Minton) | Held |
|---|---|---|---|
| Admissibility under Ohio rape‑shield law: evidence of victim’s alleged statements she was paid for sex / past sexual history with defendant | Exclusion justified because proffer lacked temporal nexus and probative value and was unduly prejudicial under R.C. 2907.02(D) | Evidence of prior sexual activity with defendant (or paid sex) was material to consent and defendant’s Sixth Amendment confrontation rights | Court: exclusion not an abuse of discretion; no plain‑error constitutional violation because probative value was minimal and State interests outweighed it |
| Evidence about origin of pregnancy / statements naming other fathers | State: origin already addressed by DNA and evidence; trial court properly excluded statements that were collateral or aimed at impeachment and were barred by rape‑shield statute | Argued such statements were relevant to paternity and to undermine conception allegation against him | Court: origin of pregnancy not material to consent and evidence was offered for impeachment; rape‑shield exclusion proper |
| Cross‑examination and extrinsic proof of alleged prior false accusations | State: prior allegations were not shown to have been made or, if sexual activity occurred, excluded by rape‑shield; extrinsic evidence barred under Boggs | Sought to present witnesses and cross‑examine about prior false accusations to impeach credibility | Court: Boggs controls — only victim may be cross‑examined about totally unfounded accusations; defendant failed to show accusations were made and totally false; extrinsic evidence properly excluded |
| Sufficiency/force element and manifest weight | State: victim’s testimony, age disparity, physical descriptions, victim’s reactions, and Minton’s statements support force element and convictions | Minton: insufficient evidence of force; victim not credible; challenged various rulings and prosecutor’s comments | Court: evidence—physical acts, age/size disparity, emotional impact, and position of authority—supported force; convictions supported by sufficient evidence and not against manifest weight |
Key Cases Cited
- State v. Gardner, 59 Ohio St.2d 14 (Ohio 1979) (limits on introducing reputation/prostitution evidence; probative value must outweigh prejudice)
- State v. Boggs, 63 Ohio St.3d 418 (Ohio 1992) (prior false rape accusations: inquiry allowed only if accusations were totally unfounded; extrinsic evidence barred)
- State v. Eskridge, 38 Ohio St.3d 56 (Ohio 1988) (force in rape cases depends on ages/relationship; parental or in‑loco‑parentis authority can supply coercion)
- Rock v. Arkansas, 483 U.S. 44 (U.S. 1987) (defendant’s constitutional right to testify is fundamental but subject to reasonable limitations)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for sufficiency: viewing evidence in light most favorable to prosecution, any rational trier of fact could find guilt beyond reasonable doubt)
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight review and standard distinction from sufficiency)