State v. Reyes-Rosales
2016 Ohio 3338
Ohio Ct. App.2016Background
- Defendant Megan Reyes-Rosales, a nurse employed at a residential children’s home, was indicted on two counts of sexual battery and tried by jury.
- Victim Z.H., age 17, had been adjudicated delinquent and placed at the Wilson Children’s Home by juvenile court order.
- State witnesses (Children’s Services Executive Director and the Home Superintendent) testified Z.H. was a resident placed by court order and that staff, including Reyes-Rosales, had supervisory authority over residents as part of a team.
- Z.H. testified he initiated sex and that Reyes-Rosales could not discipline him; Reyes-Rosales initially denied but later admitted sexual conduct (oral sex) with Z.H. in an office at the home.
- Jury convicted Reyes-Rosales of sexual battery under R.C. 2907.03(A)(6) (victim in custody of law and offender has supervisory or disciplinary authority) and acquitted on the other count; she was sentenced to community control and classified a sex offender.
- On appeal she argued (1) insufficiency and manifest weight of the evidence, (2) erroneous denial of specific jury instructions, and (3) trial court improperly took judicial notice of the juvenile’s confinement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency and manifest weight: whether evidence established victim was “in custody of law” and defendant had “supervisory or disciplinary authority” under R.C. 2907.03(A)(6) | State: testimony showed Z.H. was placed at the home by court order and staff (including Reyes-Rosales) had supervisory responsibility, supporting conviction | Reyes-Rosales: victim was not a prisoner/inmate and she had no supervisory or disciplinary authority over Z.H. | Affirmed: jury could credit testimony that Z.H. was in custody by court order and that Reyes-Rosales had supervisory authority; conviction was supported and not against manifest weight |
| Jury instructions: whether requested instructions on custody, coercion, and consensual sex should have been given | State: standard instructions covered statutory elements; requested instructions were incorrect, repetitive, or inapplicable | Reyes-Rosales: requested instructions required to correctly frame law (custody = prisoner; must show misuse of state-conferred power; consensual sex legal if 16+) | Affirmed: requested instructions were incorrect statements of law, repetitive, or irrelevant (A(6) is strict-liability for custodial settings) |
| Judicial notice: whether trial court improperly took judicial notice that Z.H. was confined to the home | State: court could rely on testimony and record; any judicial notice argument unsupported | Reyes-Rosales: trial court took judicial notice of court order committing Z.H. to the home | Affirmed: record shows no judicial notice was taken; issue for jury and admission by witnesses rendered judicial notice unnecessary |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence review) (1979)
- State v. Jenks, 61 Ohio St.3d 259 (standard for sufficiency review under Ohio law)
- State v. Tenace, 109 Ohio St.3d 255 (motions for acquittal and sufficiency standard)
- State v. Thompkins, 78 Ohio St.3d 380 (standard for manifest-weight review)
- State v. Manocchio, 138 Ohio St.3d 292 (statutory interpretation principles; reading undefined statutory terms in common usage)