State v. Snowden, 2014 Ohio 2299

Defendant Terrence Snowden was convicted by a jury of four counts of murder (proximate result) with firearm specifications and two counts of having weapons while under disability; aggregate sentence 36 years to life.
On appeal Snowden raised two issues: (1) the trial court excused a prospective juror ("Juror 11") for cause over defense objection, allegedly based in part on a mental disability (OCD) without exploring reasonable accommodations; and (2) the trial court imposed consecutive sentences without making the findings required by R.C. 2929.14(C).
Voir dire record: Juror 11 stated he was ‘‘OCD,’’ repeatedly expressed that he would ‘‘question [him]self’’ and might be unable to reach or sign a verdict, said he would ‘‘probably follow the law’’ on aiding-and-abetting instructions but would find it ‘‘hard,’’ and expressed a strong inclination to distrust testimony from drug users.
The prosecutor moved to excuse Juror 11 for cause; the defense opposed. The trial court held a chambers hearing, found the juror said many things that, in totality, made him unsuitable under Crim.R. 24, and excused him for cause over the defense objection.
On sentencing the court failed to state on the record the statutory findings required for consecutive sentences under R.C. 2929.14(C); the State conceded error on that point.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Snowden)	Held
Whether excusal of Juror 11 for cause was improper because it rested in part on a mental disability without considering reasonable accommodation	Juror 11 described pathological doubt and indecision that would prevent him from deciding or signing a verdict; his statements made him unsuitable and not amenable to accommodation; Speer (physical-impairment rule) does not apply	Juror 11 agreed he would follow the law, trusted some recovering addicts, and his meticulousness (OCD traits) could be accommodated; excluding him for disability violated rights without exploring accommodations	Affirmed: no abuse of discretion. The court found Juror 11 repeatedly expressed inability to reach a verdict, doubt about following the law, and bias against drug-using witnesses; Speer (physical-impairment accommodation rule) did not apply to mental condition.
Whether consecutive sentences were imposed without required statutory findings	State concedes the trial court failed to make R.C. 2929.14(C) findings and requests remand for findings	Snowden argues sentencing error because the court made no required findings for consecutive terms	Reversed in part and remanded: sentencing court must place R.C. 2929.14(C) findings on the record and re-sentence accordingly.

State v. Speer, 925 N.E.2d 584 (Ohio 2010) (trial court must consider reasonable accommodations before excusing a juror for cause based on a physical impairment)
Berk v. Matthews, 559 N.E.2d 1301 (Ohio 1990) (challenge for cause determination is reviewed for abuse of discretion)
Huffman v. Hair Surgeons, Inc., 482 N.E.2d 1248 (Ohio 1985) (abuse of discretion defined as unreasonable or arbitrary)
AAAA Enterprises, Inc. v. River Place Community Urban Redevelopment Corp., 553 N.E.2d 597 (Ohio 1990) (decision unreasonable when no sound reasoning process supports it)