State v. Redmond, 2022 Ohio 3734

Defendant Jonathan Redmond (25) was indicted on six first-degree felony counts (five rape counts, one kidnapping) for events alleged to have occurred October 6, 2018 involving victim C.M., then 16.
C.M. testified at a two-day bench trial that Redmond forced oral sex, multiple acts of vaginal penetration (on the couch, in a hallway by a bathroom, and back on the couch), and cunnilingus, despite her verbal refusals and crying; she described being held, carried, and unable to escape.
C.M. delayed reporting the incident for weeks; she discussed it with a family friend and her mother before making a police report in late 2018 and again reopening the investigation in 2020; a pediatrician documented her report and emotional state in December 2018.
Defense presented the sister (D.M.), who testified about family marijuana use and produced photos/videos from shortly after the incident showing play behavior; defense argued consent and attacked credibility.
The trial court found Redmond guilty on all counts and sentenced him to an aggregate four-year prison term (concurrent terms) and Tier III sex-offender classification; Redmond appealed arguing insufficiency, manifest weight, ineffective assistance of counsel, and defective jury waiver.

Issue	State's Argument	Redmond's Argument	Held
Sufficiency of evidence (force element for rape & kidnapping)	Evidence (C.M.'s detailed testimony) established force/compulsion beyond a reasonable doubt	Insufficient proof of force; sex was consensual	Affirmed — evidence sufficient when viewed in light most favorable to prosecution
Manifest weight of evidence (credibility conflicts)	Trial court as factfinder reasonably credited C.M.; inconsistencies were minor or explained	Testimony and post-incident conduct (photos, return visits, delay) undercut credibility	Affirmed — not an exceptional case warranting reversal; court did not lose its way
Ineffective assistance of counsel	Counsel attacked credibility and made tactical choices; no prejudice shown	Counsel failed to press stronger Crim.R.29 arguments and failed to impeach C.M. with prior statements about internet recordings	Affirmed — strategic choices were reasonable; defendant did not show deficient performance or prejudice; alleged extrinsic impeachment not in record should be raised in postconviction relief
Jury waiver compliance (R.C. 2945.05)	Waivers were written, executed in open court, and defendant acknowledged consultation with counsel	Trial court failed to confirm defendant understood rights waived	Affirmed — record shows voluntary, knowing, intelligent written waivers executed in open court

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for sufficiency and defining manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (jury/verifier standard for sufficiency of evidence review)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
State v. Bradley, 42 Ohio St.3d 136 (1989) (counsel ineffectiveness standard under Ohio law)
State v. Madrigal, 87 Ohio St.3d 378 (2000) (failure to prove either Strickland prong obviates need to consider the other)
State v. Wilson, 113 Ohio St.3d 382 (2007) (manifest-weight considerations and credibility determinations)
State v. Lomax, 114 Ohio St.3d 350 (2007) ("in open court" requirement for jury waiver)
State v. Fitzpatrick, 102 Ohio St.3d 321 (2004) (presumptively valid written jury waiver)
State v. Martin, 20 Ohio App.3d 172 (1984) (standard for reversing on manifest weight — "exceptional case")
State v. Cook, 65 Ohio St.3d 516 (1992) (deference to trial counsel's strategic choices)