State v. Renaud
2017 Ohio 8218
| Ohio Ct. App. | 2017Background
- Renaud was indicted in January 2016 on multiple counts (rape, sexual battery, gross sexual imposition) concerning his stepdaughter A.T. (born 2000).
- Dates in the indictment were amended at trial from May–Sept 2013 to March–Dec 2013.
- Jury found Renaud guilty on all counts; sexual-battery counts merged into rape counts for sentencing.
- Sentencing: indefinite life terms for each rape count; five-year terms for GSI counts; sentences consecutive.
- A.T. testified to a recurring pattern of abuse in basement bedrooms, including touching and digital penetration beginning when she was about 12.
- Text messages between A.T. and her mother, detailing the abuse and disclosure steps, were admitted as evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Renaud argues insufficient evidence, lacking physical proof and precise timing. | State contends evidence, viewed favorably to prosection, proves elements beyond reasonable doubt. | Sufficient evidence supported convictions. |
| Manifest weight of the evidence | Renaud contends verdicts against weight of the evidence due to lack of physical evidence and timing/location conflicts. | State asserts jury credibility determinations allow the verdict. | Convictions not against the manifest weight. |
| Admission of text messages (hearsay) | Renaud challenges admission as hearsay not fitting Lang criteria for prior consistent statements. | State contends messages rebut defense claims; admissible under Lang or as cumulative evidence. | Admission not reversible error; not prejudicial. |
Key Cases Cited
- Jenks v. State, 61 Ohio St.3d 259 (1991) (sufficiency review standard: rational trier could find guilt beyond reasonable doubt)
- Thompkins, 78 Ohio St.3d 380 (1997) (weight-of-the-evidence standard; thirteenth juror concept)
- Otten, 33 Ohio App.3d 339 (1986) (manifest weight standard; exceptional cases required for reversal)
- Lang, 129 Ohio St.3d 512 (2011) (prior consistent statements; timing of motive to fabricate matters)
- Jenks (explicitly cited within this opinion), 61 Ohio St.3d 259 (1991) (sufficiency framework reiterated)