State v. Tillis
2017 Ohio 9010
| Ohio Ct. App. | 2017Background
- On Oct. 21, 2014, Crystal Jefferson returned home, fell asleep, and awoke to find Terrence Tillis standing in her bedroom; she says he grabbed her Michael Kors purse and fled.
- Jefferson identified Tillis (her next‑door neighbor) as the intruder, observed a broken bedroom window lock after the incident, and later received the purse back from Tillis’s girlfriend.
- Police responded, performed a protective sweep of Tillis’s residence, arrested Tillis, but did not locate the purse or collect fingerprint/DNA evidence at the time.
- A Mahoning County jury convicted Tillis of second‑degree felony burglary under R.C. 2911.12(A)(1).
- Trial court sentenced Tillis to six years’ imprisonment; Tillis filed a delayed appeal challenging sufficiency and manifest weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support burglary conviction | State: Jefferson’s eyewitness ID plus broken window lock established forced entry and presence of non‑accomplice — sufficient evidence of elements. | Tillis: Only eyewitness ID; no physical (DNA/fingerprint) evidence or independent eyewitness tying him to the purse. | Affirmed — evidence sufficient when viewed in light most favorable to prosecution. |
| Manifest weight of the evidence | State: Minor inconsistencies in timing/details do not undermine the essential proof; credibility is for the jury. | Tillis: Inconsistent timeline and conflicting details render Jefferson’s testimony unreliable; verdict against manifest weight. | Affirmed — inconsistencies were minimal and did not create a manifest miscarriage of justice. |
Key Cases Cited
- State v. Smith, 80 Ohio St.3d 89, 684 N.E.2d 668 (1997) (standard for legal sufficiency review).
- State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (1997) (distinguishing sufficiency from manifest‑weight review).
- State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (1983) (new trial on manifest weight appropriate only in extraordinary cases).
- State v. Hill, 75 Ohio St.3d 195, 661 N.E.2d 1068 (1996) (credibility determinations are for the trier of fact).
- State v. DeHass, 10 Ohio St.2d 230, 227 N.E.2d 212 (1967) (standard that appellate courts defer to jury credibility assessments).