State v. Scheffield
2017 Ohio 2593
| Ohio Ct. App. | 2017Background
- On December 27, 2011, Randy Scheffield was found dead in bed from a .22 caliber gunshot; initial investigation found no forced entry, a missing Ruger pistol (box present), and evidence collected from the scene. Coroner ruled the death a homicide.
- Appellant Doretta Scheffield (wife) gave recorded statements and maintained innocence; prosecution alleged she shot Randy between ~9:00–9:30 a.m., left the house, and created an alibi using errands, surveillance, phone records, and receipts.
- After a multi-year investigation, Doretta was indicted on multiple counts (including complicity and principal charges after a hearing); trial focused on aggravated murder and tampering with evidence (murder merged with aggravated murder). Jury convicted on aggravated murder and tampering; she was sentenced to life with parole eligibility after 25 years plus 30 months consecutive.
- Key forensic evidence: bullet in skull (.22), gunshot residue patterns, DNA: Randy’s and Doretta’s DNA on gun box/magazine and on household items; stomach contents and livor/rigor analyses produced competing time-of-death estimates (prosecution’s experts placed death in early morning hours consistent with Doretta being at home).
- Defense theory: later time of death when Doretta was away; challenged forensic timing (defense expert estimated later death). Court admitted lay opinion testimony about victim‑advocate observations and police testimony; trial court denied post‑verdict Crim.R. 29 motions and sentenced Doretta.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated murder | State: forensic and circumstantial evidence (time of death, DNA on gun box, missing gun, lack of signs of intruder, Doretta’s conduct) allowed a rational trier of fact to find prior calculation and design | Doretta: alibi corroborated by surveillance/phone/receipts; alternative timing and unknown intruder possible | Conviction upheld; evidence sufficient to sustain aggravated murder and tampering convictions |
| Manifest weight of the evidence | State: jury reasonably credited prosecution experts and inferences; defense timing disputed but less persuasive | Doretta: jury lost its way given conflicting expert testimony on time of death | No; appellate court found verdict not against manifest weight — jury credibility determinations upheld |
| Admissibility of Victim Advocate (lay) testimony | State: testimony about observed demeanor and funeral behavior was lay opinion helpful to understanding facts | Doretta: witness improperly gave expert-style opinions about "trauma behavior" and credibility | Admissible as lay opinion under Evid.R. 701; not reversible error |
| Detective testimony / counsel effectiveness | State: police testimony describing investigative observations and motives was proper or harmless | Doretta: detective’s comments improperly vouched for veracity or suggested motive; counsel ineffective for not objecting | Most challenged statements were factual or harmless; failure to object did not prejudice under Strickland; ineffectiveness claim denied |
| Fifth Amendment at sentencing | Doretta: court punished silence / lack of allocution by imposing harsher sentence | State: court may consider lack of remorse as statutory factor, but cannot penalize silence alone | No Fifth Amendment violation; court explicitly noted lack of remorse stemmed from continued claim of innocence and considered statutory sentencing factors appropriately |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency of evidence review follows Jackson v. Virginia)
- Jackson v. Virginia, 443 U.S. 307 (1979) (reasonable-doubt sufficiency standard for criminal convictions)
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for manifest-weight review)
- State v. Bradley, 42 Ohio St.3d 136 (1989) (two-prong ineffective-assistance test adopting Strickland)
- Strickland v. Washington, 466 U.S. 668 (1984) (performance and prejudice standard for ineffective assistance)
- Malloy v. Hogan, 378 U.S. 1 (1964) (Fifth Amendment self-incrimination applies to the states)
- Mitchell v. United States, 526 U.S. 314 (1999) (silence at sentencing cannot be used against defendant)
- State v. Lang, 129 Ohio St.3d 512 (2011) (objection preservation and plain-error standard)