State v. Fields

Citations

• 2022 Ohio 620

Syllabus

Joinder indictments severance plain error Crim.R. 8 Crim.R. 13 Crim.R. 14 right to be present Confrontation Clause Sixth Amendment Crim.R. 43 waiver disruptive sufficiency of the evidence circumstantial evidence direct evidence manifest weight of the evidence ineffective assistance of counsel cross-examination competency cumulative error consecutive sentences. Appellant failed to demonstrate how he was prejudiced when the trial court joined his three separate indictments for one trial and did not sever them once the crimes relating to one of the indictments were dismissed after the close of the state's case. The trial court did not violate the appellant's Sixth Amendment right to be present at trial when appellant was removed from the courtroom after he continuously disrupted trial proceedings. The state produced sufficient direct and circumstantial evidence to sustain convictions for each of the appellant's crimes. Further, the jury did not find the appellant guilty against the manifest weight of the evidence. Appellant's trial counsel's cross-examination, decision not to seek severance, and not renew the issue of competency were all decisions of trial strategy and did not rise to the level of ineffective assistance. Because we did not find error in any of appellant's assignments of error, appellant was not deprived of a fair trial under the cumulative error doctrine. Finally, the trial court did not err in imposing consecutive sentences because the trial court made the requisite statutory findings and those findings were supported by evidence in the record.