State v. Reed, 2023 Ohio 878

Background

Reed ran an in‑home daycare and cared for three children, including 17‑month‑old "Brian."
On Nov. 4, 2020 Brian appeared normal at lunch on a video call at about 12:30 p.m.; roughly 30 minutes later Reed showed Brian on a video call unresponsive on the floor.
Emergency responders transported Brian to Dayton Children’s Hospital, where doctors found multiple subdural hemorrhages, diffuse brain injury, and retinal hemorrhages consistent with abusive head trauma (shaken‑baby syndrome).
The state’s child‑abuse pediatrician, Dr. Kelly Liker, testified that the injuries were not consistent with short‑distance falls and were most consistent with forceful, repetitive shaking with or without impact.
Reed testified and denied causing the injuries, offered various inconsistent accounts of how Brian was injured, and presented no expert rebuttal; the jury convicted her of felonious assault and felony child endangerment and acquitted on related misdemeanors.
Reed appealed, arguing juror bias and prejudice from live streaming (due process/fair trial), and that her convictions were unsupported by sufficient evidence and were against the manifest weight of the evidence. The court affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror bias / challenge for cause	Court should permit juror to serve because relationship was casual and trial court has discretion to rule on cause	Reed: juror knew a state witness and should have been excused for cause; panel may have been tainted	Trial court did not abuse discretion; juror was casual, excused before deliberations, and no evidence any seated juror was biased
Live streaming / separation of witnesses	State: court may control proceedings; witnesses were instructed not to view stream	Reed: live stream could have violated the separation‑of‑witnesses order and prejudiced her trial	No prejudice shown; Reed did not seek mistrial or ask for admonition and could have cross‑examined on the issue; claim denied
Sufficiency of evidence	State: expert and circumstantial evidence permitted a rational juror to find Reed caused the injuries	Reed: evidence does not prove she inflicted the injuries; other medical explanations or earlier injury possible	Evidence sufficient: expert linked timing and injury mechanism to abuse while in Reed’s care; circumstantial proof supported conviction
Manifest weight of the evidence	State: jury reasonably credited expert and witness testimony; Reed’s inconsistent statements weakened defense	Reed: verdict against the greater weight of credible evidence; expert equivocations create reasonable doubt	Not against manifest weight: jury did not lose its way; credibility determinations and circumstantial inferences support conviction

Key Cases Cited

State v. Bryan, 101 Ohio St.3d 272 (2004) (trial court’s ruling on challenge for cause reviewed for abuse of discretion)
McQueen v. Scroggy, 99 F.3d 1302 (6th Cir. 1996) (knowing parties is not per se disqualifying)
State v. Hale, 119 Ohio St.3d 118 (2008) (juror acquaintance with parties/witnesses not automatically disqualifying)
State v. Beasley, 153 Ohio St.3d 497 (2018) (casual/distant relationships do not require excusal)
Ross v. Oklahoma, 487 U.S. 81 (1988) (constitutional challenge must show an actually seated juror was partial)
State v. Richey, 64 Ohio St.3d 353 (1992) (trial court has discretion to control witnesses and sequester)
State v. McGuire, 80 Ohio St.3d 390 (1997) (orders on trial proceedings subject to trial court discretion)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest‑weight standard explained)
State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency of the evidence standard following Jackson)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency: any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Wilks, 154 Ohio St.3d 359 (2018) (framework for manifest‑weight review)
State v. Williams, 79 Ohio St.3d 1 (1997) (claims of juror misconduct must focus on seated jurors)
Martin v. Ohio, 20 Ohio App.3d 172 (1st Dist. 1983) (manifest‑weight test explained)
Johnson v. Abdullah, 166 Ohio St.3d 427 (2021) (credibility determinations rest with the factfinder)