State v. Shaw, 2016 Ohio 7699

In Sept. 2014 Dennis Davis was indicted on multiple counts of sexual crimes (including first‑degree rape) and a warrant issued; task force learned he was engaged to Cletissia Shaw.
Deputy U.S. marshals visited Shaw’s home twice; on both visits she initially delayed answering and consented to searches but denied Davis was present.
On the second, full task force search, officers found Davis hiding naked inside a snap‑lid storage tote with a box on top; he held a gun to his head and was apprehended.
Shaw was charged with obstructing justice under R.C. 2921.32(A)(1) and (C)(4) (felony of the third degree where aided person committed a first‑degree felony and defendant knew or had reason to believe it).
Following a jury trial Shaw was convicted and sentenced to three years of community control; she appealed alleging (1) ineffective assistance of counsel and (2) the verdict was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the verdict was against the manifest weight of the evidence	Evidence (officers’ testimony, physical circumstances of tote, Shaw’s denials) shows Shaw knowingly harbored/ concealed Davis to hinder apprehension	Shaw consented to two searches and there was no credible evidence she assisted Davis or obstructed his arrest	Court: Affirmed conviction—jury reasonably found Shaw lied and helped conceal Davis; weight claim fails
Whether Shaw received ineffective assistance of counsel for not objecting to opening statement and testimony about Davis’s crimes	State asserts any omission was harmless given strength of evidence and jury instruction that opening statement is not evidence	Shaw argues counsel should have objected to prejudicial details about Davis’s underlying charges and the indictment’s admission	Court: No ineffective assistance—performance not shown to have prejudiced outcome given strong evidence of harboring

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for manifest‑weight review)
State v. Martin, 20 Ohio App.3d 172 (1983) (manifest‑weight reversal is reserved for exceptional cases)
State v. Shuttlesworth, 104 Ohio App.3d 281 (1995) (ineffective assistance overview)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑part test for ineffective assistance)
State v. Hale, 119 Ohio St.3d 118 (2008) (applying Strickland in Ohio)
State v. Sanders, 94 Ohio St.3d 150 (2002) (definition of reasonable probability of prejudice)
State v. Bradley, 42 Ohio St.3d 136 (1989) (judicial deference in reviewing counsel performance)
State v. Holloway, 38 Ohio St.3d 239 (1988) (failure to object alone insufficient for ineffective assistance)