State v. Thompson
2016 Ohio 7521
| Ohio Ct. App. | 2016Background
- Craig Thompson was indicted for complicity to commit burglary after co-defendant Brad Burns entered Charles Fox’s home and took property; Thompson was alleged to have driven Burns to the house, shown him where a spare key and the safe were, and planned to split the money.
- First trial (April 2014) ended in a mistrial (hung jury); Thompson moved to dismiss on double-jeopardy grounds unsuccessfully; retrial in December 2015 resulted in conviction and a six-year prison sentence.
- Key evidence: Burns’s trial testimony implicating Thompson; Burns’s hotel key and phone were found in Thompson’s truck; Thompson’s truck was parked near the victim’s house shortly after the crime; an invoice for work at the victim’s address and text messages between Thompson and Shai Bathini showing financial need.
- Thompson moved to suppress evidence from a traffic stop and challenged the stop’s length and Miranda warnings; he also contested admission of Bathini’s text messages, alleged ineffective assistance of counsel, and argued his sentence was enhanced for exercising trial rights.
- The trial court denied suppression; the court of appeals affirmed the conviction, rejecting claims on sufficiency/weight of evidence, suppression, hearsay/authentication of texts, ineffective assistance, and judicial vindictiveness at sentencing.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Thompson) | Held |
|---|---|---|---|
| Sufficiency / Weight of Evidence | Burns’s testimony, physical items from coat and truck, truck location, invoice, and texts support complicity and intent. | Insufficient: Thompson didn’t aid or intend to aid; brother Brandon provided information; witnesses unreliable. | Affirmed: Burns’s testimony alone was sufficient; credibility issues go to weight not sufficiency. |
| Motion to Suppress (traffic stop length & Miranda) | Stop and continued detention were supported by articulable, evolving suspicion; Miranda given after arrest at station. | Stop was unreasonably prolonged; custodial interrogation occurred in cruiser without Miranda. | Denied: detention reasonably extended by new facts; no Miranda violation shown because custodial interrogation did not occur until after warnings. |
| Admission of text messages | Texts were admissions by party-opponent and properly authenticated by recipient Bathini; probative value not substantially outweighed by prejudice. | Texts were hearsay, unauthenticated, unfairly prejudicial, and some were late in discovery. | Denied: defendant forfeited specific hearsay/authentication objections; texts admissible as party-opponent statements and not unduly prejudicial. |
| Ineffective Assistance of Counsel | N/A (responding to defendant’s claim) | Counsel failed to refile suppression, object to evidence, pursue juror issues, call witnesses, or move for delayed jury deliberation. | Denied: counsel’s actions were reasonable trial strategy; defendant failed to show deficient performance or prejudice. |
| Sentencing—vindictive for going to trial | N/A | Judge punished Thompson for exercising right to jury trial and referenced prior trial PTSD / irritation. | Denied: record did not show sentence enhancement due to exercise of trial right; comments did not create an inference of vindictive sentencing. |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (standards for sufficiency review)
- State v. Thompkin s, 78 Ohio St.3d 380 (manifest-weight review explanation)
- State v. Burnside, 100 Ohio St.3d 152 (mixed question of law and fact on suppression)
- Rodriguez v. United States, 135 S. Ct. 1609 (limits on prolonging traffic stops for unrelated checks)
- Berkemer v. McCarty, 468 U.S. 420 (Miranda custodial-interrogation principles during stops)
- Strickland v. Washington, 466 U.S. 668 (ineffective-assistance two-prong test)