State v. Newett
2016 Ohio 7605
| Ohio Ct. App. | 2016Background
- Defendant Darnell Newett was tried for the March 2013 homicide of Rhonda Jackson and convicted by a jury of aggravated murder, murder, felonious assault, aggravated robbery, aggravated burglary, kidnapping, and tampering with evidence; aggregated sentence 35 years to life.
- Victim suffered over 70 stab/cutting wounds, blunt force injuries, and cervical compression; death certified homicide.
- Forensic evidence recovered from a dumpster near the scene included blood-stained jeans, boots, gloves, and a knife; DNA testing linked Newett as major contributor on clothing interiors and Jackson as contributor to exterior bloodstains and items.
- Witnesses placed Newett and Jackson as acquaintances with a strained relationship; testimony that Newett threatened Jackson after believing she had set him up for prior burglaries; a neighbor observed Newett had “freshened up” the day of the murder.
- Defense presented an alibi witness who said she drove Newett earlier in the day and dropped him off in the early evening; defense argued contamination of scene and alternative suspects were not fully investigated.
Issues
| Issue | State's Argument | Newett's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated murder (prior calculation and design) | Evidence (threats, relationship strain, choice of knife, gloves, clothing change, bloodied clothing with Newett’s IDs) shows prior calculation and design | Evidence insufficient; circumstantial and contaminated forensics do not establish prior calculation | Affirmed: reasonable minds could find prior calculation and design based on circumstantial and forensic evidence |
| Sufficiency of evidence for felony-murder / aggravated murder under R.C. 2903.01(B) (during aggravated robbery) | Underlying aggravated robbery shown by theft of victim’s wallet and infliction of serious physical harm causing death | Argues no proof of robbery and contamination undermines link between Newett and theft | Affirmed: evidence supports aggravated robbery as predicate and felony-murder theory |
| Sufficiency of evidence for aggravated robbery | DNA on victim’s wallet and missing money supports attempted/committed theft while inflicting serious harm | Contention that evidence was contaminated and alternate suspects existed | Affirmed: evidence and circumstantial proof sufficient for conviction |
| Manifest weight of the evidence for murder conviction | Forensic, circumstantial, and testimonial evidence collectively persuasive; jury properly credited witnesses | Verdict against manifest weight due to possible contamination and investigative gaps | Affirmed: jury did not lose its way; not an exceptional case warranting reversal |
Key Cases Cited
- State v. Bridgeman, 381 N.E.2d 184 (Ohio 1978) (standard for sufficiency review—evidence supports conviction if reasonable minds could reach different conclusions)
- State v. Taylor, 676 N.E.2d 82 (Ohio 1997) (factors for prior calculation and design inquiry)
- State v. Coley, 754 N.E.2d 1129 (Ohio 2001) (prior calculation and design can exist despite quick conception and execution)
- State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (distinguishing sufficiency from manifest weight review)
- State v. Lang, 954 N.E.2d 596 (Ohio 2011) (circumstantial and forensic evidence may support convictions)