State v. Thomas (Slip Opinion), 92 N.E.3d 821

Victim Annie McSween was found murdered near a Mentor-on-the-Lake bar on Nov. 26, 2010; cause of death was a stab wound severing the carotid artery and jugular, with additional evidence of strangulation, sexual assault, and postmortem stab wounds.
Joseph L. Thomas was identified as a patron at the bar that night; circumstantial evidence placed him in the vicinity afterward (neighbor saw a man near a burn barrel behind Thomas’s residence; burned remnants of McSween’s clothing were recovered from the barrel).
No murder weapon was recovered; forensic testing found partial male Y-STR profiles on the victim’s underwear and vaginal swab that did not exclude Thomas but were not definitive; no direct DNA, fingerprints, or blood linking Thomas to the scene or victim were found.
Police seized five knives from Thomas’s belongings (none were shown to be the murder weapon); the state introduced those knives at trial and emphasized them to the jury, describing them as “Rambo combat knives.”
Thomas was convicted of aggravated murder and related felonies, sentenced to death; on appeal he raised 24 propositions, and the Ohio Supreme Court reversed and remanded based on plain error in admitting the unrelated knives into evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of five knives unrelated to the crime	Knives were relevant to identity/motive and to show access to a knife consistent with wounds	Knives were "other acts" evidence used to show propensity; irrelevant and highly prejudicial under Evid.R. 404(B)	Admission was plain error: knives were unrelated and impermissibly used to show violent character; reversal required
Plain-error standard	N/A (state)	Thomas: admission was obvious error that affected substantial rights and outcome	Court applied plain-error review and found reasonable probability the error affected outcome; reversed
Whether evidence was harmless given circumstantial case	N/A (state argued weight of other evidence supports conviction)	Thomas: admission was prejudicial because case lacked overwhelming independent evidence; knives inflamed jury and confused issues about murder weapon	Court: not an overwhelming-evidence case; error prejudiced defendant; reversal warranted
Remedy	N/A	Thomas sought a new trial	Court reversed convictions and death sentence and remanded for a new trial

State v. Neyland, 139 Ohio St.3d 353 (Ohio 2014) (admission of unrelated weapons was harmless where overwhelming independent evidence existed)
State v. Trimble, 122 Ohio St.3d 297 (Ohio 2009) (analysis of when ownership/possession of weapons can be relevant vs. impermissible other-acts evidence)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (plain-error review framework)
State v. Rogers, 143 Ohio St.3d 385 (Ohio 2015) (defendant must show reasonable probability that error resulted in prejudice)
United States v. Dominguez Benitez, 542 U.S. 74 (U.S. 2004) (standard for reasonable probability of prejudice)
State v. Webb, 70 Ohio St.3d 325 (Ohio 1994) (harmless-error principle for admission of other acts/weapons)
State v. Long, 53 Ohio St.2d 91 (Ohio 1978) (plain-error correction limited to exceptional circumstances)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (circumstantial evidence can support conviction)