State v. Quinn, 2026-Ohio-2578

Quinn was convicted in 2005 of kidnapping and repeatedly raping a 16-year-old victim, and this court affirmed those convictions on direct appeal. 1
The victim identified Quinn soon after the attack, and police found clothing, scratches, and a distinctive tattoo matching her description. 2
Forensic testing on the victim's underwear and body swabs found Quinn's DNA in mixtures from the underwear, breast, and neck swabs. 3
Quinn later obtained court-authorized independent testing of the vaginal swabs, which found no foreign victim DNA and a Y-STR profile consistent with Quinn. 4
Quinn then moved for expert funds to interpret the DNA results and for a new trial, but the trial court denied both motions. 5
The trial court held the DNA results did not exclude Quinn and that his new-trial request was procedurally defective because he did not seek leave. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Quinn was entitled to expert funds for DNA review 7	Quinn said expert help was needed to reconcile confusing DNA results.	The State said Quinn failed to show need and had not provided basic cost information.	No abuse of discretion; expert funds properly denied. 8
Whether Quinn was entitled to a new trial based on the DNA results 9	Quinn claimed the new DNA evidence justified a new trial.	The State said the motion was untimely and Quinn never sought leave.	No abuse of discretion; new trial properly denied. 10

Ake v. Oklahoma, 470 U.S. 68 (U.S. 1985) (due process may require state-funded expert assistance for an indigent defendant 11)
State v. Mason, 82 Ohio St.3d 14 (Ohio 1998) (indigent defendant must make a particularized showing that expert aid is reasonably probable to help and denial would be unfair 12)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (defines abuse of discretion as unreasonable, arbitrary, or unconscionable 13)