State v. Shaw
2016 Ohio 923
Ohio Ct. App.2016Background
- Maurice Shaw was charged with murder-related offenses after DNA from under the victim’s fingernails and a doorknob was later analyzed by a third party and linked to him.
- Shaw challenged the DNA methodology at a Daubert hearing; the trial court admitted the third-party DNA results.
- On the day his trial was to begin, Shaw accepted a plea deal: guilty pleas to involuntary manslaughter, aggravated burglary, and having a weapon while under disability; he agreed sentences would total between 15–23 years.
- Shortly before sentencing Shaw (pro se) moved to withdraw his plea; his three appointed attorneys also moved to withdraw as counsel. The court appointed two new attorneys, held a hearing, granted counsel’s withdrawal, and denied Shaw’s motion to withdraw his plea.
- The trial court sentenced Shaw to an aggregate 17-year prison term. Shaw appealed, challenging (1) the admissibility of the DNA evidence and (2) the denial of his motion to withdraw his plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of third‑party DNA analysis | State: DNA results were admissible and linked Shaw to the scene. | Shaw: DNA methodology unreliable; trial court erred in admitting results. | Overruled on appeal — plea waived evidentiary challenge. |
| Motion to withdraw guilty plea (coercion) | State: Shaw’s plea was voluntary, made after a full Crim.R. 11 colloquy and competent counsel; his post‑plea claims are self‑serving. | Shaw: He was coerced by three attorneys and his father during a six‑hour session the day of trial; lacked discovery and felt pressured. | Denied by trial court and affirmed on appeal — record shows plea was knowingly, voluntarily, intelligently entered; coercion not shown. |
| Counsel’s motions to withdraw | State: trial court properly appointed new counsel and proceeded to sentencing. | Shaw: (no successful challenge) | Trial court granted counsel’s motion to withdraw; appellate court affirmed proceedings were proper. |
| Actual innocence / discovery access | State: independent evidence (witness ID, co‑defendant testimony, stolen goods sales) supported prosecution; Shaw admitted guilt in PSI. | Shaw: Lack of access to discovery and questions about DNA reliability undermined voluntariness and actual innocence claim. | Court found discovery complaint irrelevant to plea withdrawal; no actual innocence claim shown sufficient to withdraw plea. |
Key Cases Cited
- Daubert v. Merrell Dow Pharm., 509 U.S. 579 (U.S. 1993) (standards for admissibility of scientific expert testimony)
- State v. Ketterer, 855 N.E.2d 48 (Ohio 2006) (guilty plea waives many pretrial evidentiary challenges)
- State v. Xie, 584 N.E.2d 715 (Ohio 1992) (abuse‑of‑discretion standard for pre‑sentence plea withdrawal)
- State v. Kapper, 448 N.E.2d 823 (Ohio 1983) (self‑serving affidavits insufficient to rebut record showing plea was voluntary)
- State v. Fitzpatrick, 810 N.E.2d 927 (Ohio 2004) (guilty plea effects on appealability of issues)