State v. Rios, 2012 Ohio 3289

Juan Rios was convicted in Clark County, Ohio, of aggravated murder and related offenses for killings at Club Lavaca.
Two victims, Misael Nunez and Arnulfo Claudio, were fatally shot; a gun found in a church lot matched the weapon used.
DNA on the murder weapon and Rios’s pants, and gunshot residue on his hands, were linked to the killings.
Rios had a prior felony cocaine conviction and a firearms disability without evidence of restoration.
DNA testing was conducted at BCI after the court ordered external testing to allow defense expert presence; trial occurred in September 2010.
The jury sentenced Rios to life without parole for aggravated murders, with additional concurrent and consecutive counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
DNA testing without expert present violated due process	State contends no exculpatory value evident prior testing	Rios asserts due process violation due to lack of expert presence	No due process violation; no preexisting exculpatory value shown
Verdicts were against the manifest weight of the evidence	State argues witnesses' credibility supports convictions	Rios claims inconsistencies show miscarriage of justice	Convictions not against the weight of the evidence
Sufficiency of evidence supports specified counts	State demonstrates sufficient proof of intent to rob and shoot	Rios argues insufficiency for theft-related elements	Sufficient evidence supported the counts

California v. Trombetta, 467 U.S. 479 (U.S. 1984) (exculpatory value for destroyed evidence must be apparent)
State v. Martin, 20 Ohio App.3d 172 (Ohio App.3d 1983) (standard for reviewing sufficiency of evidence)
State v. Jenks, 61 Ohio St.3d 259 (Ohio St. 1991) (sufficiency test: reasonable doubt when viewed in light favorable to prosecution)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (establishes standard for manifest weight and credibility review)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility and witness evaluation belong to factfinder)