State v. Watts

Citations

• 2020 Ohio 3282

Syllabus

Complicity R.C. 2903.02 aiding and abetting aggravated murder R.C. 2903.01(B) murder R.C. 2903.02(A) and (B) aggravated burglary R.C. 2911.11(A)(1) felonious assault R.C. 2903.11(A)(1) kidnapping R.C. 2905.01(A)(3) sufficiency and manifest weight of the evidence allied offenses effective assistance of counsel. Defendant's convictions were affirmed because the state presented sufficient circumstantial evidence to prove beyond a reasonable doubt that defendant was complicit in the crimes against the victim and the trier of fact did not clearly lose its weight when it found defendant guilty. Thus, defendant's convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. Further, there was no error when the trial court did not merge defendant's aggravated murder and kidnapping convictions because the evidence showed that the restraint of the victim was prolonged such that there was a separate animus for kidnapping and aggravated murder and thus, counsel was not ineffective for failing to object to the trial court's merger analysis.