State v. Thompson, 2020 Ohio 5257

In Aug. 2018 Michael Thompson confessed to Cleveland police that he killed an African‑American woman (D.G.) in the mid‑1990s, sketched a burial site, and led officers to remains recovered in Sept. 2018. The remains were bound and wrapped.
Autopsy: fatal stab wound to the right temple; manner of death ruled a homicide.
Police identified the remains as D.G.; investigation tied her last being seen in 1996.
The State sought and the trial court admitted Evid.R. 404(B) evidence of two prior attacks (1989 and 1995) in which Thompson allegedly bound and assaulted African‑American women; one prior incident included Thompson’s DNA on the victim.
Thompson waived a jury and had a bench trial; the court convicted him of murder, aggravated murder (during kidnapping), and kidnapping and sentenced him to life with parole eligibility after 20 years.
On appeal Thompson challenged (1) admission of 404(B) evidence, (2) sufficiency of the evidence, and (3) manifest weight; the appellate court affirmed, finding the 404(B) ruling erroneous but harmless because the judge did not rely on the other‑acts evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior bad acts (Evid.R. 404(B))	404(B) evidence was admissible to show modus operandi, plan, intent, and absence of mistake.	Evidence was irrelevant, improperly propensity evidence, and more prejudicial than probative.	Admission was erroneous: prior acts were propensity evidence not tied to a proper non‑propensity purpose, but error was harmless because the bench judge did not consider it.
Sufficiency of the evidence for kidnapping and murder	Physical and forensic evidence (bindings, stab wounds, autopsy) and Thompson’s confession support convictions.	Bindings could have been postmortem or consensual; confession alone is insufficient.	Sufficient evidence existed; a rational trier of fact could find elements proven beyond a reasonable doubt.
Manifest weight of the evidence	State’s forensic evidence and the finder of fact’s credibility assessments support convictions.	Thompson’s account explained events (heat‑of‑passion/consensual elements); conflicting evidence undermines verdict.	Convictions are not against the manifest weight; trial judge did not clearly lose its way.

Blakemore v. Blakemore, 450 N.E.2d 1140 (Ohio 1983) (abuse‑of‑discretion standard for appellate review of trial court rulings)
State v. Williams, 983 N.E.2d 1278 (Ohio 2012) (three‑step test for admissibility of other‑acts evidence under Evid.R. 404(B))
State v. Lowe, 634 N.E.2d 616 (Ohio 1994) (modus operandi evidence and identity)
State v. Smith, 551 N.E.2d 190 (Ohio 1990) (use of other‑acts as proof of scheme or plan)
Huddleston v. United States, 485 U.S. 681 (U.S. 1988) (relevance inquiry for other‑acts evidence)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (standard for reviewing sufficiency and manifest‑weight claims)
State v. Jenks, 574 N.E.2d 492 (Ohio 1991) (standard for sufficiency of the evidence)
State v. Darmond, 986 N.E.2d 971 (Ohio 2013) (discussing abuse‑of‑discretion review for evidentiary rulings)