State v. White, 2015 Ohio 3512

Samuel White was convicted of felony murder for Coatney's death in April 2012 after a trial in 2014.
Prosecution evidence linked White to the murder via a blue Tahoe, shell casings, and White’s statements to Adell Lawrence.
White offered an alibi defense, claiming he was at a movie theater with his girlfriend Ivery at the time of the shooting.
Cell-site/phone-location testimony placed White’s phone within specific cell-tower sectors on the night of the murder.
Detectives recovered a gun matching the casings, found on the riverbank, and linked to White’s purchase a week before the murder.
The trial court instructed the jury on flight as consciousness of guilt, and White appealed raising five assignments of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Cell-sector testimony reliability	Horan’s cell-site analysis is reliable under Daubert/Kumho standards.	Analysis ignores factors affecting tower choice and lacks testing/peer review.	Assignment overruled; testimony deemed reliable.
Admission of prior threats evidence	Threats show long-standing motive against Coatney.	Threats too remote and unreliable for probative value.	Assignment overruled; threat admissible for motive.
Sufficiency and weight of the evidence	Evidence tied White to the scene and to the gun; sufficient for conviction.	Gaps and inconsistencies undermine credibility and causation.	Assignments overruled; evidence supports both sufficiency and weight.
Flight instruction	Flight evidence properly admitted as consciousness of guilt.	Flight instruction was unnecessary and potentially prejudicial.	Assignment overruled; instruction harmless beyond a reasonable doubt.
Ineffective assistance of counsel	Counsel failed to challenge potentially exculpatory video and cross-examine inconsistencies.	Counsel’s strategy was reasonable; cross-examination and preservation efforts were adequate.	Assignment overruled; no deficient performance shown.

Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (U.S. 1993) (gatekeeping reliability standard for expert testimony)
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (U.S. 1999) (flexible application of Daubert factors to technical testimony)
State v. Drummond, 2006-Ohio-5084 (Ohio) (gatekeeping applicable to expert testimony in Ohio)
State v. Snowden, 49 Ohio St.2d 7, 359 N.E.2d 87 (Ohio 1976) (probativeness of prior acts requires relevant temporal relationship)
State v. Cruse, 2008-Ohio-4039 (Ohio) (threats admissible to show purpose to kill with appropriate time proximity)
State v. Sage, 31 Ohio St.3d 173, 510 N.E.2d 343 (Ohio 1987) (admissibility of flight evidence under standard discretion)