State v. Stanforth
2017 Ohio 4040
| Ohio Ct. App. | 2017Background
- Henry Stanforth was indicted on one count of importuning and two counts of gross sexual imposition for sexual conduct with two young girls (charged dates June–Nov. 2014). Jury convicted on all counts.
- Victims (P.E. and A.E.) testified to grooming (fishing, four-wheeling, money/candy, overnight stays) and distinct sexual acts: P.E. said Stanforth touched her vagina and had her touch his penis; A.E. said he showed her his penis.
- A prior alleged victim (A.L.) testified about substantially similar past grooming and abuse (admitted as other-acts evidence to show plan, motive, absence of mistake).
- Mother recorded two conversations with Stanforth; he denied wrongdoing but gave inconsistent explanations (e.g., saying children saw him urinating or claiming accidental exposure).
- Trial court sentenced Stanforth to consecutive terms totaling 13 years. He appealed raising five assignments of error (admission of other-acts evidence, merger/double jeopardy/due process, sufficiency/weight, and ineffective assistance of counsel).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of other-acts (Evid.R. 404(B)) | Other-acts (A.L.) show plan, motive, absence of mistake and corroborate victims' accounts | A.L.'s testimony was unduly prejudicial and should be excluded as character evidence | Court affirmed admission: relevant for plan/motive; limiting instructions given; probative not substantially outweighed by unfair prejudice |
| Sufficiency / manifest weight of evidence | State: victim testimony, recorded denials, grooming pattern, corroboration suffice | Stanforth: evidence insufficient or against manifest weight | Court held convictions supported by sufficient evidence and not against manifest weight; jury credibility determinations upheld |
| Merger / double jeopardy for two GSI counts (Counts 2 & 3) | State: counts charged distinct acts (one where victim touched his penis, one where he touched her vagina) | Stanforth: counts indistinct/duplicative, violated due process/double jeopardy (cites Valentine/Hemphill) | Court held counts were separate, specific acts; bill of particulars and testimony tied each count to distinct conduct; no merger or constitutional violation |
| Ineffective assistance of counsel | N/A for state; defense argued counsel failed to adequately cross-examine and pursue distinguishing details | Stanforth: counsel failed to press victims on physical details, was potentially unsympathetic | Court rejected claim: counsel’s choices were reasonable trial strategy; no prejudice shown under Strickland |
Key Cases Cited
- State v. Williams, 134 Ohio St.3d 521 (Ohio 2012) (framework for admitting other-acts evidence under Evid.R. 404(B))
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance standard: deficient performance and prejudice)
- Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005) (insufficient specificity in charging/treatment of multiple sexual acts can violate due process/double jeopardy)