State v. Wilson, 2014 Ohio 461

Defendant Charles E. Wilson was indicted on two counts of felonious assault (second degree) and one count of assault on a peace officer (fourth degree).
Defendant sought not guilty by reason of insanity; competency evaluations were ordered and eventually found competent to stand trial.
Counsel for defendant withdrew and new counsel was appointed; a grievance against counsel was filed but the court denied withdrawal to avoid trial disruption.
A jury identified Wilson as the attacker; Lee testified to the assault and identified Wilson, with corroboration from officers at the scene.
DNA testing on clothing and shoes linked blood to Lee and possibly Ayers, and blood on the right shoe had two possible contributors; chain of custody was challenged but details were admitted for jury consideration.
Wilson was convicted on all counts and sentenced to eight years on each felonious assault count, plus eighteen months for the assault on a peace officer, with other penalties for post-release control violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conflict-of-interest withdrawal decision	Wilson argues trial court erred by not adequately inquiring into a conflict.	Wilson contends a grievance against counsel created a conflict affecting representation.	No abuse of discretion; court properly inquired and resolved conflict.
Sufficiency and weight of the evidence	State asserts sufficient evidence supported guilt beyond a reasonable doubt.	Wilson challenges credibility of Lee, DNA, and chain of custody.	Convictions supported by sufficient evidence and not against the manifest weight.

State v. Cowans, 87 Ohio St.3d 68 (1999) (abuse-of-discretion standard for withdrawal decisions)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion involves unreasonable, arbitrary, or unconscionable action)
State v. Gillard, 64 Ohio St.3d 304 (1992) (duty to inquire into actual conflict of interest when counsel’s representation is questioned)
State v. Yarbrough, 95 Ohio St.3d 227 (2002) (credibility determination left to the trier of fact)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (meaning of manifest weight standard; appellate review from entire record)
State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency of the evidence standard (jury could find guilt beyond reasonable doubt))
State v. Bradley, 42 Ohio St.3d 136 (1989) (two-prong test for ineffective assistance of counsel)
Semedo, 5th Dist Stark No. 2006-CA-00108, 2007-Ohio-1805 (2007) (chain of custody considerations affect weight, not admissibility)