State v. Sari, 2021 Ohio 944

Ameen Sari was indicted on attempted unlawful sexual conduct with a minor, importuning, and possession of criminal tools after an ICAC undercover officer (posing as a 15-year-old on Whisper) engaged Sari in sexually explicit messages and arranged a park meeting where Sari was arrested.
Trial occurred in March 2020; voir dire revealed Prospective Juror No. 16 said her 10-year-old daughter had been the victim of an online predator and thanked ICAC for catching the offender.
Juror No. 16 told the court she would likely be unable to be fair; the court excused her for cause after questioning outside the venire.
Defense did not request a mistrial at that time or object to the court’s resolution beyond seeking dismissal for cause.
The jury convicted Sari on all counts; he was sentenced to two years community control and Tier II sex-offender registration for 25 years.
On appeal Sari raised two issues: (1) trial court erred by not declaring a mistrial because Juror No. 16 allegedly unduly influenced the venire; (2) trial counsel was ineffective for failing to move for a mistrial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a mistrial was required because a prospective juror disclosed her daughter was an online-predator victim and praised ICAC, allegedly biasing the venire	The State argued the juror was excused for cause and no mistrial was warranted	Sari argued the comment personalized the case, unduly influenced remaining jurors, and required mistrial	Court: No mistrial; juror excused, no contemporaneous objection by defense, only plain-error review, and no manifest miscarriage shown
Whether counsel was ineffective for not seeking a mistrial after the juror's comment	The State argued counsel’s choice caused no prejudice and the record shows no improper influence on the jury	Sari argued counsel’s failure was deficient and prejudiced the defense under Strickland	Court: Ineffective-assistance claim denied; defendant failed to show Strickland prejudice (no reasonable probability of a different outcome)

State v. Trimble, 911 N.E.2d 242 (Ohio 2009) (trial court has broad discretion in assessing juror impartiality)
State v. Williams, 452 N.E.2d 1323 (Ohio 1983) (voir dire determinations reviewed for abuse of discretion)
State v. Phillips, 656 N.E.2d 643 (Ohio 1995) (plain-error review to be exercised with utmost caution)
State v. Long, 372 N.E.2d 804 (Ohio 1978) (plain-error standard and cautionary principle)
State v. Drummond, 854 N.E.2d 1038 (Ohio 2006) (articulates Strickland two-prong test for ineffective assistance)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (deficient performance and prejudice required for ineffective assistance)
State v. Benge, 661 N.E.2d 1019 (Ohio 1996) (defendant must show improper influence deprived him of fair trial)