State v. Walker, 2023 Ohio 810

Walker pleaded guilty to multiple sexually oriented offenses for repeatedly sexually abusing a church youth (J.S.) beginning when she was ~14; the abuse continued for several years and reportedly occurred roughly 600 times. He was sentenced to an aggregate 4.5 years’ imprisonment.
At a Megan’s Law classification hearing, the State presented Detective Vagase’s investigative testimony recounting J.S.’s statements and reporting that Walker had propositioned several other women (no independent corroboration or charges for those women).
The trial court found a "significant pattern of abuse," noted grooming/isolation, a pattern of concealment and minimization by Walker, and classified him a sexual predator under former R.C. Chapter 2950.
On appeal Walker argued (1) the court improperly considered uncorroborated, out-of-record allegations (unreliable hearsay) about propositions to other women, and (2) the record lacked clear and convincing evidence that he is likely to reoffend (manifest-weight challenge).
The court of appeals affirmed, holding the classification was supported by clear and convincing evidence and that the trial court properly considered investigative information because evidentiary rules do not strictly apply at sex-offender classification hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court improperly relied on uncorroborated allegations about Walker propositioning other women (inadmissible hearsay)	State: investigative testimony corroborated J.S. and was probative of a pattern of conduct	Walker: those allegations were unsubstantiated, outside the record, and unreliable hearsay	Court: Rules of evidence do not strictly apply; trial court properly considered the investigative statements as reliable, probative evidence
Whether clear and convincing evidence supports sexual-predator classification (likelihood to reoffend)	State: severity, long duration (~600 incidents), grooming/abuse of position, pattern of concealment, corroborating allegations support risk of future offenses	Walker: no prior convictions beyond this relationship, low risk score, health issues, no substance use, left pastoral role — record lacks evidence of future risk	Court: Evidence (nature/extent of abuse, pattern, concealment, corroborating allegations) met clear-and-convincing standard; classification not against manifest weight

State v. Cook, 83 Ohio St.3d 404 (rules of evidence do not strictly apply in sex-offender classification hearings)
State v. Eppinger, 91 Ohio St.3d 158 (elements required for sexual-predator designation)
Cross v. Ledford, 161 Ohio St. 469 (definition of clear and convincing evidence)
State v. Wilson, 113 Ohio St.3d 382 (civil manifest-weight standard for sex-offender classifications)
Eastley v. Volkman, 132 Ohio St.3d 328 (appellate manifest-weight review principles)
State v. Thompkins, 78 Ohio St.3d 380 (discussion of manifest-weight standard)
State v. Martin, 20 Ohio App.3d 172 (weighing evidence and credibility standard)
State v. Purser, 153 Ohio App.3d 144 (court need not recite each statutory factor; psychological risk tests are not dispositive)
State v. Lee, 128 Ohio App.3d 710 (trial court may consider all cogent, probative evidence at classification hearing)