State v. Cooper

Citations

• 2025 Ohio 2007

Syllabus

Rape; admissibility of evidence; Evid.R. 70; opinion testimony by lay witnesses; delayed disclosures; post-traumatic stress disorder; sufficiency of the evidence; forcible rape; psychological force; manifest weight of the evidence. Defendant's conviction for rape of a child under 13 years old is affirmed. The trial court did not abuse its discretion when it allowed three lay witnesses to testify about their opinions pursuant to Evid.R. 701, because the testimony was rationally based on the perception of each witness and it was helpful to the jury. The rape conviction was supported by sufficient evidence in the record. Inconsistent testimony does not factor into a sufficiency analysis, a rape conviction can be based on the victim's testimony alone, and coercion can be inherent in a parental authority scenario. The rape conviction is not against the manifest weight of the evidence in the record. Although the victim testified about sexual conduct that she had not disclosed prior to trial, the defendant was convicted of one rape charge, which was consistent with the victim's disclosure, and acquitted of all other charges.