State v. White, 2020 Ohio 3313

On May 29, 2018, 17-year-old Joseph Davis was shot four times and died; defendant Gonnii White (age 16 at the time) ultimately admitted to shooting him.
White and Davis were aligned with rival neighborhood gangs (White with the Roadrunners/Crips; Davis with the Bloods); investigators recovered gang-related social media and images linked to White.
White was interviewed at the police station, waived Miranda, and confessed after detectives (falsely) told him witnesses said the shooting was in self-defense.
White was charged as an adult with murder, a firearm specification, and a gang-related specification; he moved to suppress his statement and moved in limine to exclude gang-expert testimony.
The trial court denied both pretrial motions; a jury convicted White of murder and specifications; court sentenced him to an aggregate 21 years to life.
On appeal White raised three assignments of error: denial of his suppression motion, denial of his motion in limine (gang expert), and that the verdict was against the manifest weight of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (White)	Held
Whether White's custodial statement should have been suppressed as involuntary	The interview complied with Miranda; White knowingly waived rights and confession was voluntary	Detectives lied about witnesses and that deceit overbore White's will (juvenile), making statement involuntary	Waiver was knowing and voluntary; officer's lie did not overbear White's will; suppression denied affirmed
Whether the trial court erred in admitting gang-related testimony from the detective as expert testimony	Detective had specialized training, experience, and reliable knowledge about local gangs; testimony aided the jury	Testimony should have been excluded for lack of qualification/admissibility	Court did not abuse discretion; detective qualified under Evid.R.702 and testimony admissible (also admissible as lay testimony)
Whether the conviction was against the manifest weight of the evidence	Eyewitness testimony, autopsy, White's admissions, and gang evidence supported murder beyond a reasonable doubt and disproved self-defense	White claimed self-defense — he believed Davis had a gun and posed imminent danger	Jury credibility determinations reasonable; evidence supported verdict; conviction not against manifest weight

Colorado v. Spring, 479 U.S. 564 (police deception alone does not automatically render a confession involuntary)
State v. Wesson, 137 Ohio St.3d 309 (Miranda warnings required for custodial interrogation)
State v. Barker, 149 Ohio St.3d 1 (juvenile waiver: consider age, experience, education, and capacity to understand rights)
State v. Drummond, 111 Ohio St.3d 14 (gang-expert testimony may be admitted where expert knowledge exceeds jurors')
State v. Boston, 46 Ohio St.3d 108 (expert testimony under Evid.R.702 must aid trier of fact)
State v. Robbins, 58 Ohio St.2d 74 (elements of self-defense)