State v. Turpin, 2017 Ohio 4200

Defendant Craig Turpin was indicted for multiple sex offenses involving two child victims; tried on charges related to neighbor J.H.; jury convicted him of two counts of rape of a child under 10, one count of gross sexual imposition of a child under 13, and one count of kidnapping for sexual activity; court found him a sexually violent predator and sentenced him to consecutive life terms and 5 years-to-life.
Events involving J.H. allegedly occurred Nov 2012–Jan 2013; J.H., then eight, described digital and limited penile contact, threats, and wiping “white stuff” on bedding; some physical findings (hymenal redness, scrapes) and semen on bedding and a t‑shirt recovered from Turpin’s apartment supported parts of her account, but assault kit samples from J.H. did not identify semen.
Turpin testified and denied the abuse; offered alternative explanations for recovered items, claimed travel and visitors at his apartment, and pointed to prior animus with an investigating officer.
At the separate bench SVP (sexually violent predator) hearing, the court heard testimony about Turpin’s prior sexual offenses and arrests, and his daughter H.H.’s testimony about an alleged childhood sexual assault by Turpin.
Trial court concluded the jury did not err on the convictions (no manifest miscarriage of justice) and, after considering prior convictions, probation/parole history, and the prior-victim testimony, found Turpin a sexually violent predator.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether convictions were against the manifest weight of the evidence	State: J.H.’s testimony corroborated by physical findings, recovered items, and explanations for absent DNA supported convictions	Turpin: Lack of DNA on victim, no clear penetration marks, no STI transmission, and victim not credible	Court: Affirmed convictions; jury did not lose its way; circumstantial and corroborating evidence sufficient
Whether testimony of defendant’s daughter (H.H.) at SVP hearing was inadmissible and violated Fifth Amendment	State: H.H.’s testimony relevant to SVP factors—shows chronic sexually motivated conduct and is "other relevant evidence" under R.C. 2971.01(H)(2)	Turpin: Testimony about uncharged prior acts was improper and forced him to testify, compelling self-incrimination	Court: Admitted H.H.’s testimony as relevant to SVP factors; no Fifth Amendment violation; court properly weighed credibility

State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (Ohio 1997) (articulates standard for reviewing manifest-weight claims)
State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (Ohio Ct. App. 1983) (discusses factors and approach for manifest-weight review)