State v. Carter-El

Citations

• 2025 Ohio 4842

Syllabus

Sufficiency; Crim.R. 29; manifest weight; aggravated murder; R.C. 2903.01(B); murder; R.C. 2903.02(A); R.C. 2903.02(B); aggravated robbery; R.C. 2911.01(A)(1); R.C. 2911.01(A)(3); felonious assault; R.C. 2903.11(A)(1); R.C. 2903.11(A)(2); accomplice testimony instruction; DNA evidence; surveillance-video identification; sentencing; R.C. 2929.03; R.C. 2929.11; R.C. 2929.12; R.C. 2929.19(B)(1)(b); R.C. 2953.08(G)(2); juvenile bindover; mandatory transfer; Juv.R. 30; R.C. 2152.10; R.C. 2152.12; probable cause. Judgment affirmed. The State presented sufficient evidence through surveillance footage, eyewitness identification by an accomplice, and corroborating DNA linking appellant to the vehicle involved in the crime to support convictions for aggravated murder and firearm specifications. The trial court therefore properly denied appellant's Crim.R. 29 motions. In addition, the convictions were not against the manifest weight of the evidence. The jury heard an accomplice's identification and robbery narrative, the jury could independently evaluate surveillance video and stills depicting the perpetrator the accomplice identified as appellant, and the jury received a cautionary accomplice instruction before crediting that testimony. In sentencing appellant, the trial court did not fail to consider youth as mitigation. The sentencing record expressly reflected consideration of R.C. 2929.11, 2929.12, and the youth-specific factors in R.C. 2929.19(B)(1)(b). Constitutional challenges were forfeited by failure to object. The aggregate term of 36 years to life, including consecutive three-year firearm specifications, was not clearly and convincingly contrary to law under R.C. 2953.08(G)(2). Finally, the juvenile court did not err in its mandatory bindover determination. Because appellant was 16 at the time and charged with category one and category two offenses, transfer under R.C. 2152.10 and 2152.12 was proper upon a showing of probable cause. Testimony and exhibits, includin