State v. Hicks-Stevens

Citations

• 230 N.E.3d 477
• 2023 Ohio 4307

Syllabus

Aggravated robbery having weapons while under disability speedy trial plain error continuance pandemic reasonableness voir dire jury grand jury burden of proof sufficiency identity circumstantial evidence reasonable inferences video evidence manifest weight hearsay co-conspirator statements Evid.R. 801(D)(2)(e) independent proof Confrontation Clause indefinite sentence Reagan Tokes Law. Affirmed appellant's convictions and sentence for aggravated robbery and having weapons while under disability. The trial court did not commit plain error during voir dire in differentiating the grand jury process. Appellant failed to establish any violation of his statutory or constitutional speedy-trial rights or to demonstrate plain error in regard thereto. Appellant's convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. Ample circumstantial evidence was presented, which included compelling video evidence, from which reasonable inferences could be drawn as to appellant's identity and his commission of the crimes. The trial court did not abuse its discretion in the admission of co-conspirator statements under Evid.R. 801(D)(2)(e). No sentencing error occurred by the imposition of an indefinite sentence under S.B. 201, and appellant's constitutional challenges to the Reagan Tokes Law were rejected.