State v. Springer, 2017 Ohio 8861

On Sept. 5–6, 2015, Theresa Adair left a party in a Cleveland apartment building with Carlton Springer after a verbal dispute; surveillance video shows Springer forcefully pulling Adair from an elevator and down the hallway.
Adair was later found by friends unconscious/with a swollen/gashed forehead; she was hospitalized, underwent hemicraniectomy for a massive subdural hematoma, and was declared brain dead.
Autopsy: cause of death = blunt force head trauma resulting in subdural hematoma; injuries consistent with severe force, not a simple fall.
Springer was tried by jury: acquitted of murder but convicted of felony murder (based on underlying felonious assault) and related counts; trial court merged allied counts and sentenced Springer to 15 years to life on the felony-murder count.
On appeal Springer raised seven assignments of error, principally challenging manifest weight of the evidence, ineffective assistance of counsel, prosecutorial misconduct, the trial court's response to a jury question, verdict form sufficiency, and imposition of court costs.
The appellate court affirmed convictions except it vacated the imposition of court costs and remanded for a hearing whether costs should be waived because the trial court had previously found Springer indigent.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Springer)	Held
Manifest weight of the evidence	Evidence (video, witness ID, coroner) supports that Springer caused fatal blunt-force head trauma	Witnesses were intoxicated/inconsistent; no video of actual strike; injury could be accidental fall	Affirmed: weight of evidence supports felony murder conviction—jury did not lose its way
Ineffective assistance of counsel	Trial counsel’s choices (no expert, no objections) were reasonable; no prejudice shown	Counsel failed to object to detectives' memory testimony, failed to call medical expert, failed to object to prosecutorial comments, and mishandled jury question	Overruled: no deficient performance or prejudice shown on these claims
Prosecutorial misconduct	Closing argument remarks were permissible (victim unavailable, comment on defense failure to adduce evidence)	Prosecutor shifted burden, appealed to juror sympathy, and commented on defendant silence	Overruled: comments within permissible bounds and did not deprive Springer of a fair trial
Court costs and waiver	Statute requires court costs be included in sentence; court may waive on motion	Trial court erred in imposing costs after finding indigence; counsel ineffective for not moving to waive costs	Sustained in part: vacated imposition of costs and remanded for hearing on waiver due to prior indigency finding

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest-weight standard and "thirteenth juror" review)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
Tibbs v. Florida, 457 U.S. 31 (U.S. 1982) (appellate court as thirteenth juror concept)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility and weight of evidence are for the trier of fact)
State v. Pelfrey, 112 Ohio St.3d 422 (Ohio 2007) (verdict forms must indicate degree or aggravating element)
United States v. Hasting, 461 U.S. 499 (U.S. 1983) (trial need not be error-free; focus on fairness of trial)