State v. Yates
2015 Ohio 3087
Ohio Ct. App.2015Background
- Defendant Denzil Yates was indicted for aggravated murder (with firearm spec), murder (with firearm spec), and tampering with evidence after James Anderson was shot multiple times and died.
- Police found a firearm under a vehicle following footprints from the scene to the gun; gloves with Yates’s DNA and gunshot residue linked him to the weapon; Yates made statements to police admitting he had the gun and directed officers to where it was hidden.
- Yates initially sought to plead guilty to murder (count two) in exchange for dismissal of other counts and a sentencing recommendation; at the plea hearing he expressed mental-health concerns and denied purposely killing the victim; the trial court rejected the plea.
- Yates rejected an Alford plea offered by the state and elected to go to trial; at trial the jury acquitted him of aggravated murder but convicted him of murder and tampering with evidence; sentence totaled 21 years to life.
- On appeal Yates argued (1) the court erred by rejecting his guilty plea, (2) trial counsel was ineffective for not pressing the plea/Alford option, and (3) the court should have instructed the jury on voluntary manslaughter.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Yates) | Held |
|---|---|---|---|
| Whether trial court abused discretion by refusing Yates’s guilty plea | Court may refuse pleas; plea appeared inconsistent with evidence and defendant’s own denials | Trial court wrongly blocked a knowing, voluntary guilty plea and denied opportunity for Alford plea | Trial court did not abuse discretion; plea was not knowing/voluntary and Alford was rejected by Yates |
| Whether counsel was ineffective for not objecting to plea rejection or seeking Alford resolution | Counsel’s performance was reasonable; omission did not prejudice outcome | Counsel failed to preserve plea option and thus rendered ineffective assistance leading to harsher sentence | No ineffective assistance; defendant cannot show deficient performance or prejudice under Strickland |
| Whether the jury should have received a voluntary manslaughter instruction | No sufficient evidence of sudden passion or serious provocation to support instruction | Victim’s threats and charging behavior justified voluntary manslaughter instruction | No; evidence did not show reasonably sufficient provocation—trial court properly declined instruction |
| Appropriate standard for reviewing refusal to give a requested instruction | Trial court has discretion, but instruction must be given if evidence warrants | (raised in concurrence) Instruction entitlement should be reviewed de novo as a legal question | Majority applies abuse-of-discretion standard; concurring judge urges de novo review for legal sufficiency of evidence to warrant an instruction |
Key Cases Cited
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (plea may be entered while maintaining innocence under certain circumstances)
- Santobello v. New York, 404 U.S. 257 (U.S. 1971) (trial court may reject plea in exercise of discretion)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part ineffective assistance standard: deficient performance and prejudice)
- State v. Elmore, 111 Ohio St.3d 515 (Ohio 2006) (voluntary manslaughter is an inferior-degree offense to murder; provocation standard explained)
- State v. Shane, 63 Ohio St.3d 630 (Ohio 1992) (provocation must be reasonably sufficient to arouse an ordinary person beyond control to warrant manslaughter instruction)
- State v. Sneed, 63 Ohio St.3d 3 (Ohio 1992) (defendant entitled to requested charge that is pertinent, correct, and not covered by general charge)