State v. Rawls
2016 Ohio 7962
| Ohio Ct. App. | 2016Background
- In 1996 Rawls was convicted after a Marc’s store robbery where employees were bound with red T‑shirts; eyewitnesses and phone/pager link evidence implicated him. He received an aggregate 18–50 year sentence.
- Rawls maintained innocence and, in 2015, applied for postconviction DNA testing of the T‑shirts used to bind the victims.
- The prosecutor submitted a report that investigators could not locate the T‑shirts after searching county and Euclid PD records, the county evidence room, prior prosecutors, and trial files.
- The report, however, revealed inconsistencies: a Euclid police report and federal-court pleadings indicated two items of clothing had been held as evidence as recently as 2010.
- The trial court denied an evidentiary hearing and denied testing, finding the evidence did not exist and that DNA testing would not be outcome determinative.
- The Eighth District reversed and remanded, holding the state’s investigative report did not show reasonable diligence and the court erred by denying a hearing and failing to explain the outcome‑determinative conclusion.
Issues
| Issue | State's Argument | Rawls' Argument | Held |
|---|---|---|---|
| Whether court erred by refusing an evidentiary hearing on existence/location of T‑shirts | APA report showed searches of police, property room, county evidence, prosecutors; no items found, so no hearing required | APA’s search was incomplete and superficial; the court should hold a hearing to probe custodians and records given conflicting evidence | Reversed and remanded for hearing — court abused discretion by relying on insufficient report to conclude evidence did not exist |
| Whether DNA testing would be outcome‑determinative under R.C. 2953.74(C)(5) | Even if shirts exist, touch DNA likely degraded and results wouldn’t exclude Rawls because shirts could have been handled by others | DNA exclusion could be outcome‑determinative given identity was contested at trial and clothing was used by perpetrator | Reversed — trial court failed to state reasons and erred in concluding testing would not be outcome‑determinative |
Key Cases Cited
- State v. Ayers, 185 Ohio App.3d 168, 923 N.E.2d 654 (2009) (standard of appellate review for postconviction DNA testing applications)
- State v. Adams, 62 Ohio St.2d 151, 404 N.E.2d 144 (1980) (abuse of discretion defined)