State v. Sferro
2016 Ohio 7257
| Ohio Ct. App. | 2016Background
- On Nov. 8, 2014, Renaldo Sferro and Michael Haught engaged in a road‑rage altercation; Sferro admitted spraying Haught with pepper spray during the incident.
- Sferro later returned, reported to police that Haught had pulled a gun on him, and initially omitted that he had used pepper spray until police noted residue on Sferro’s neck.
- Officer Gerald Rose found Sferro’s account vague and inconsistent, investigated, and charged Sferro with falsification under R.C. 2921.13(A)(2) for knowingly making a false statement to incriminate Haught.
- At bench trial, witnesses who observed the incident testified they did not see a gun; Haught denied possessing or brandishing a weapon at the time.
- The trial court found Sferro guilty, imposed a $100 fine and suspended 30‑day jail sentence on one year probation; Sferro appealed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Sferro) | Held |
|---|---|---|---|
| Admissibility of >10‑yr old conviction for impeachment (Evid.R. 609(B)) | N/A (State opposed introduction of old conviction by defense witness) | Trial court erred by excluding a 22‑year‑old conviction on cross to impeach Haught | Affirmed: Exclusion proper — no Evid.R. 609(B) notice and record inadequate to review probative vs. prejudicial balancing |
| Sufficiency of evidence for falsification (Crim.R. 29) | Sufficient evidence showed Sferro knowingly made false statement to incriminate Haught | State failed to prove Sferro knowingly lied about a gun being brandished | Affirmed: Evidence sufficient for conviction; inferences favor State |
| Manifest weight of the evidence | N/A | Conviction is against the manifest weight; evidence favors Haught | Affirmed: Credibility determinations supported conviction; not an exceptional case to reverse |
Key Cases Cited
- Keaton v. Abbruzzese Bros., Inc., 189 Ohio App.3d 737 (2010) (trial court discretion in admitting >10‑year‑old convictions under Evid.R. 609(B))
- Thompkins v. Ohio, 78 Ohio St.3d 380 (1997) (standard for reviewing sufficiency of the evidence)
- Jenks v. Ohio, 61 Ohio St.3d 259 (1991) (deference to trier of fact; all reasonable inferences drawn for the State when assessing sufficiency)
- Otten v. Ohio, 33 Ohio App.3d 339 (9th Dist. 1986) (manifest‑weight standard and rarity of reversal)
- Martin v. Ohio, 20 Ohio App.3d 172 (1st Dist. 1983) (discussing reversal only in exceptional manifest‑weight cases)