State v. Snelling
2011 Ohio 3222
Ohio Ct. App.2011Background
- Dodd met Snelling in late 2009 and moved in with him with her 4-year-old son.
- Dodd decided to end the relationship around year-end; she left the home and planned to retrieve her belongings.
- On December 31, 2009, Snelling drove Dodd around for hours, refused to let her out, and headed toward various locations.
- They eventually drove onto I-71; Dodd attempted to jump out, Snelling chased and prevented her from exiting.
- Police pursued Snelling after he fled; he crashed, fled on foot, discarded a box cutter, and was restrained after a struggle; he was found with a police scanner.
- Snelling was charged with abduction, two counts of failure to comply with police, and assault on a police officer; he was convicted on all counts and sentenced, with merger on the failure-to-comply counts resulting in a two-year term.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effective assistance of counsel analysis | Snelling | Snelling | Overruled |
| Admission of prior-incident and box cutter evidence | Snelling | Snelling | Overruled |
| Rebuttal testimony and recall of witness | Snelling | Snelling | Overruled |
Key Cases Cited
- State v. Hamblin, 37 Ohio St.3d 153 (Ohio 1988) (ineffective-assistance standard; presumption of competence)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (nyct; standard for ineffective assistance of counsel)
- State v. Bradley, 42 Ohio St.3d 136 (Ohio 1989) (performance below reasonable standard; prejudice prong)
- State v. Long, 53 Ohio St.2d 91 (Ohio 1978) (plain-error review; exceptional circumstances)
- State v. McNeill, 83 Ohio St.3d 438 (Ohio 1998) (limitations on rebuttal evidence; discretionary discretion)