State v. Wright, 2011 Ohio 3575

Indicted July 2007 for rape and four counts of unlawful sexual conduct with a minor (S.P.), alleged to have occurred from 2002 to 2004.
S.P. testified she began a relationship with Wright around age 12–13 and that Wright spent substantial time with her family.
Over years, Wright allegedly had intercourse with S.P. at multiple locations; S.P. became pregnant (child born 2005).
DNA testing indicated Wright as the father with 99.99% probability; Jackson testified about their relationship and past knowledge.
A videotaped interview and other witnesses corroborated ongoing sexual contact; Wright was convicted on all counts and sentenced to 25 years.
The trial court admitted out-of-state events and DNA evidence related to paternity; appellate court later vacated certain convictions and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of age element for unlawful sexual conduct with a minor	State argues circumstantial evidence shows Wright was over 18 and ten years older.	Wright contends no direct or adequate circumstantial proof of age.	Age element not proven; convictions for unlawful sexual conduct vacated.
Admission of other acts to prove scheme/identity	State asserts West Virginia/Tennessee acts show common scheme and aid identity.	Wright argues acts were not inextricably related and not admissible for identity.	Improper admission of other acts; rape conviction reversed and remanded for new trial.
Speedy-trial rights	State argued delays were within statutory tolling; delays did not violate speedy-trial right.	Wright contends delays violated the 270-day rule.	No violation; trial within the 270-day limit considering tolls.
Effect of counsel conduct and pro se claims	N/A	Wright cannot show reversible error for counsel withdrawals or self-representation claims.	Arguments overruled; no ineffective assistance shown.
Veridic and procedural sufficiency of verdict forms	N/A	Failure to file verdict forms is not reversible when record shows conviction.	No reversible error; forms not required to be filed to affect substantial rights.

State v. Thompson, 66 Ohio St.3d 496 (Ohio Supreme Court 1981) (limitations on other-acts evidence; chronology of acts and identity not always controlling)
State v. Curry, 43 Ohio St.2d 66 (Ohio Supreme Court 1975) (common scheme/plan exception for other acts evidence)
State v. Flonnory, 31 Ohio St.2d 124 (Ohio Supreme Court 1972) (limitations on admissibility of other-acts evidence)
State v. Jenks, 61 Ohio St.3d 259 (Ohio Supreme Court 1991) (sufficiency of evidence standard; standard for review)
State v. Price, 80 Ohio App.3d 35 (Ohio App. 1992) (element proof beyond a reasonable doubt; circumstantial evidence permitted)