History
  • No items yet
midpage
2022 Ohio 2370
Ohio Ct. App.
2022
Read the full case

Background

  • Just after midnight on Sept. 23, 2020, an unknown man (Strietelmeier) rang Rhonda Mapes’ doorbell for several minutes, searched around the porch and her car, and returned to a car parked in her driveway.
  • Colerain Township officers arrived, found Strietelmeier in the car, told him no one named “Brandy” lived at that address and advised him not to return; no bodycam of that encounter.
  • About 2:15 a.m., Strietelmeier returned, rang the Mapes’ doorbell again, peered through glass, banged the doorframe, jerked the handle, and walked toward the rear of the house, later arrested near a Penske truck.
  • On arrest he said he was looking for “Brandy” at the direction of his girlfriend Donna and that he used the house’s Spanish arches as a visual cue; he claimed confusion and possible untreated mental illness.
  • A jury convicted him of criminal trespass under R.C. 2911.21(A)(1); the municipal court imposed a 30‑day jail term stayed, two years’ probation, 200 hours community service, and a $250 fine. The First District affirmed on appeal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether conviction was against the manifest weight for failure to prove Strietelmeier knowingly entered/ remained without privilege State: He returned after being warned, engaged in conduct (peering, handling door, lingering) from which knowledge and lack of permission can be inferred; jury credibility findings control Strietelmeier: He reasonably believed he had permission (looking for Brandy per Donna); police told him they didn’t know who lived there and didn’t specifically prohibit returning to the Mapes’ house; may have been mentally impaired Court affirmed: jury could credit state; knowledge may be inferred; no requirement that owner post notice; privilege not proven; verdict not against manifest weight
Whether alleged mental illness required reversal or competency inquiry State: No competency claim or mental‑illness defense was pursued at trial Strietelmeier: Claimed possible untreated mental illness impaired his understanding Court: Defense didn’t request competency or present mental‑illness defense at trial, so the issue was not preserved for appellate reversal

Key Cases Cited

  • State v. DeHass, 10 Ohio St.2d 230, 227 N.E.2d 212 (Ohio 1967) (credibility and weight of evidence are for the trier of fact)
  • State v. Janson, 183 Ohio App.3d 377, 917 N.E.2d 296 (1st Dist. 2009) (no requirement that property post “no trespassing” signs to support trespass conviction)
  • State v. Foster, 153 N.E.3d 728 (8th Dist. 2020) (knowledge may be reasonably inferred from victim’s demeanor and others’ interactions)
Read the full case

Case Details

Case Name: State v. Strietelmeier
Court Name: Ohio Court of Appeals
Date Published: Jul 8, 2022
Citations: 2022 Ohio 2370; C-210409
Docket Number: C-210409
Court Abbreviation: Ohio Ct. App.
Log In