State v. Strutz, 2011 Ohio 3660

Strutz was tried in Hamilton County, Ohio, and convicted of murder, abuse of a corpse, and two counts of tampering with evidence, with dismemberment-related charges arising from Kristen Strutz's disappearance.
The court imposed consecutive prison terms: five years for each tampering count, 15-to-life for murder, and one year for abuse of a corpse, for a total of 26 years to life.
Key physical evidence included Kristen's torso found in a black garbage bag in Strutz's trash can and bone fragments with saw-tooth marks at a site near his house.
Circumstantial factors included Kristen's text about going to the store, her purse in Strutz's car, the car in the driveway with the ignition key, and Kristen's crutches left at home.
Strutz bought garbage bags the day Kristen disappeared, and purchased Clorox and a mop; authorities found items moved from the yard to a garbage can, and saws possibly used for dismemberment were involved.
On appeal, Strutz challenged character-evidence rulings, admissibility of prior consistent statements, sufficiency/weight of the evidence, and the legality of consecutive sentences; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of character evidence	State contends the testimony showed motive and was probative.	Strutz argues the evidence was irrelevant and prejudicial.	First assignment overruled.
Admissibility of prior consistent statements	State argues 801(D)(1)(b) applies to rebut recent fabrication.	Strutz seeks to admit recordings to bolster his credibility.	Second assignment overruled; recordings inadmissible under 801(D)(1)(b).
Sufficiency and weight of the evidence	State asserts overwhelming circumstantial evidence proves murder and dismemberment.	Strutz contends the evidence is insufficient or against weight of the evidence.	Evidence sufficient; no manifest weight issue; convictions affirmed.
Consecutive-sentencing under Ice/Hodge	State maintains consecutive sentences are permissible after Hodge.	Strutz argues Ice requires different treatment or remand.	Consecutive sentences affirmed; post-Hodge framework applied.

State v. Long, 53 Ohio St.2d 91 (1978) (plain-error review and evidentiary standards)
State v. Wilson, 74 Ohio St.3d 381 (1996) (evidence of motive relevant to crimes)
State v. Burrell, 2005-Ohio-34 (Ohio App. Dist. 1) (prior consistent statements and admissibility)
State v. Grays, 2001-Ohio-8679 (12th Dist.) (impeachment and prior consistent statements guidance)
State v. Yarber, 1995 (Ohio App.3d) (impeachment and admissibility considerations)
State v. Martin, 20 Ohio App.3d 172 (1983) (sufficiency of circumstantial evidence standard)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest weight and sufficiency framework)
State v. Barnes, 2008-Ohio-1854 (6th Dist.) (constructive knowledge and tampering evidence guidance)
Oregon v. Ice, 555 U.S. 160 (2009) (consecutive-sentencing framework at the federal level)
State v. Hodge, 128 Ohio St.3d 1 (2010) (post-Ice treatment in Ohio sentencing statutes)