State v. Biggs

CourtOhio Court of Appeals
DecidedJune 17, 2026
Docket2025CA00103, 2025CA00104
StatusPublished

This text of State v. Biggs (State v. Biggs) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Biggs, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Biggs, 2026-Ohio-2298.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT STARK COUNTY, OHIO

STATE OF OHIO, Case No. 2025CA00103 2025CA00104 Plaintiff - Appellee Opinion And Judgment Entry -vs- Appeal from the Stark County Court of JAY L. BIGGS, Common Pleas, Case No. 2008-CR-0653

Defendant - Appellant Judgment: Affirmed

Date of Judgment Entry: June 17, 2026

BEFORE: Craig R. Baldwin; Kevin W. Popham; David M. Gormley, Judges

APPEARANCES: KYLE L. STONE, Prosecuting Attorney, VICKI L. DESANTIS, Assistant Prosecuting Attorney, for Plaintiff-Appellee; ERIKA LAHOTE, NICHOLAS ALLEN, Assistant Public Defenders, for Defendant-Appellant.

Baldwin, P.J.

{¶1} The appellant, Jay L. Biggs, appeals from two judgment entries of the Stark

County Court of Common Pleas denying his motion for leave to file a motion for new trial

and dismissing his petition for postconviction relief. The appellee is the State of Ohio.

STATEMENT OF FACTS AND THE CASE

{¶2} In 2008, the appellant was indicted in the Stark County Court of Common

Pleas on charges of aggravated murder, murder, rape, and endangering children in

connection with the death of his infant daughter.

{¶3} The State argued at trial that the appellant sexually assaulted his daughter

and then caused her death by smothering or otherwise obstructing her breathing. The

State presented medical testimony concerning injuries to the child’s genitalia and the cause and manner of death. Dr. Bertin, a urologist consulted during the autopsy process,

testified to findings he interpreted as traumatic injury to the vaginal area. Dr. P.S. Murthy,

the Stark County Coroner, testified concerning the autopsy findings and opined that the

appellant’s daughter died as a result of asphyxia due to smothering or compression of the

nose and mouth. Dr. Lisa Kohler testified in rebuttal for the State.

{¶4} The appellant denied responsibility. The defense called Dr. Werner Spitz, a

forensic pathologist. Dr. Spitz disputed significant portions of the State’s medical theory

and challenged whether the State had established sexual assault or smothering.

{¶5} Following the trial, the jury found the appellant guilty. The trial court

sentenced the appellant to life in prison without the possibility of parole. The appellant

pursued a direct appeal, and this Court affirmed his convictions. See State v. Biggs, 2009-

Ohio-6885 (5th Dist.). The appellant later pursued additional postjudgment litigation,

including litigation concerning access to tissue slides and other materials. This Court

affirmed prior trial-court rulings in those proceedings. See State v. Biggs, 2013-Ohio-

3333 (5th Dist.); State v. Biggs, 2016-Ohio-5305 (5th Dist.); State v. Biggs, 2020-Ohio-

6691 (5th Dist.).

{¶6} In 2024, the appellant filed a motion for leave to file a delayed motion for a

new trial under Crim.R. 33 and a successive petition for postconviction relief under R.C.

2953.21 and R.C. 2953.23. In support, the appellant relied primarily upon newly obtained

expert reports from Dr. Stephen Guertin and Dr. Janice Ophoven, medical literature or

guidelines concerning suspected child sexual abuse, and materials concerning trial

counsel’s alleged failure to consult or present additional experts.

{¶7} The appellant argued that the new expert reports and updated medical

standards undermined the State’s trial evidence. The defense experts opined that J.B.’s hymen and genital anatomy were intact or normal, that the State’s interpretation of

discoloration and other findings was flawed, that histological review was important to

confirm suspected abuse-related findings, and that the medical evidence did not establish

sexual assault or homicidal smothering.

{¶8} The State opposed the filings. The State argued, among other things, that

the appellant had not demonstrated he was unavoidably prevented from discovering the

evidence upon which he relied; that the new reports were not newly discovered evidence,

but new opinions concerning evidence and materials existing at the time of trial; that

medical literature and guidelines were not new scientific evidence; that the claims were

barred by res judicata or otherwise failed to satisfy the statutory requirements for

successive postconviction relief; and that the appellant had not shown a hearing was

required.

{¶9} The trial court denied the appellant’s motion for leave to file a delayed

motion for new trial and dismissed the successive petition for postconviction relief. The

trial court concluded that the appellant failed to satisfy the threshold requirements for

the relief requested.

{¶10} The appellant filed a timely notice of appeal and raised the following three

assignments of error:

{¶11} “I. THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT FAILED TO

GRANT BIGGS’ MOTION FOR LEAVE TO FILE A MOTION FOR NEW TRIAL WHEN

THE RECORD AND CIRCUMSTANCES DEMONSTRATED BY CLEAR AND

CONVINCING PROOF THAT HE WAS UNAVOIDABLY PREVENTED FROM

DISCOVERING THE NEW EVIDENCE.” {¶12} “II. THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT FAILED TO

HOLD AN EVIDENTIARY HEARING ON BIGGS’ MOTION FOR LEAVE TO FILE A

MOTION FOR NEW TRIAL WHEN HE SET FORTH A PRIMA FACIE CASE THAT HE

WAS UNAVOIDABLY PREVENTED FROM DISCOVERING THE NEW EVIDENCE.”

{¶13} “III. THE TRIAL COURT ERRED WHEN IT DISMISSED BIGGS’

POSTCONVICTION PETITION WITHOUT A HEARING WHEN THE RECORD SHOWS

THAT (1) HE WAS UNAVOIDABLY PREVENTED FROM DISCOVERY OF THE FACTS

UPON WHICH HE RELIES, AND (2) BUT FOR CONSTITUTIONAL ERROR IN HIS

TRIAL, NO REASONABLE FACTFINDER WOULD HAVE FOUND HIM GUILTY.”

I., II.

{¶14} In his first and second assignments of error, the appellant argues that the

trial court erred by failing to grant his motion for leave to file a motion for a new trial and

by failing to hold a hearing on that motion. We disagree.

STANDARD OF REVIEW

{¶15} We review the trial court’s denial of the motion for leave to file a motion for

a new trial under an abuse of discretion standard. State v. Schiebel, 55 Ohio St.3d 71

(1990). It is also within the sound discretion of the trial court to determine whether a

motion for a new trial and the material submitted with the motion warrant an evidentiary

hearing. State v. Hill, 1992-Ohio-43. An abuse of discretion implies more than an error of

law or judgment; instead, it connotes that the trial court’s attitude is unreasonable,

arbitrary, or unconscionable. Blakemore v. Blakemore (1983), 5 Ohio St.3d 217, 219.

When applying the abuse of discretion standard, an appellate court may not simply

substitute its judgment for that of the trial court. Id. ANALYSIS

{¶16} Crim.R. 33(B) states:

Application for a new trial shall be made by motion which, except for

the cause of newly discovered evidence, shall be filed within fourteen days

after the verdict was rendered, or the decision of the court where a trial by

jury has been waived, unless it is made to appear by clear and convincing

proof that the defendant was unavoidably prevented from filing his motion

for a new trial, in which case the motion shall be filed within seven days

from the order of the court finding that the defendant was unavoidably

prevented from filing such motion within the time provided herein.

Motions for new trial on account of newly discovered evidence shall

be filed within one hundred twenty days after the day upon which the

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Bluebook (online)
State v. Biggs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-biggs-ohioctapp-2026.