State v. Boggs

2020 Ohio 616
CourtOhio Court of Appeals
DecidedFebruary 24, 2020
Docket19CA011453
StatusPublished
Cited by1 cases

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Bluebook
State v. Boggs, 2020 Ohio 616 (Ohio Ct. App. 2020).

Opinion

[Cite as State v. Boggs, 2020-Ohio-616.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

STATE OF OHIO C.A. No. 19CA011453

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE JAMIE L. BOGGS COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellant CASE No. 18CR097844

DECISION AND JOURNAL ENTRY

Dated: February 24, 2020

CALLAHAN, Presiding Judge.

{¶1} Defendant-Appellant, Jamie Boggs, appeals from his convictions in the Lorain

County Court of Common Pleas. This Court affirms.

I.

{¶2} Late one evening in January, the police received two calls, approximately one

hour apart, about gunshots having been fired in a residential area. Several officers reported to

the area to investigate, but were unable to locate the source of the gunshots. One of those

officers, Officer James Wise, was patrolling the same area about two hours later when he

glanced down a side street and saw a pick-up truck heading toward him. The truck caught his

attention because the driver was operating it without headlights despite the pitch-black

conditions. Officer Wise decided to turn around and wait for the truck. As soon as the truck

reached the intersection, however, it turned away from his cruiser and quickly accelerated in the

opposite direction. Officer Wise then activated his lights and attempted to stop the truck. 2

{¶3} The driver of the truck led Officer Wise on a brief chase through the

neighborhood and struck a car and sign along the way. The chase ended when the truck crashed

into a fire hydrant, and Officer Wise arrested the driver and his passenger, Mr. Boggs. While

searching the truck at the scene, the police discovered a gun case from which the firearm

appeared to be missing. Officer Wise then questioned Mr. Boggs about the gun, and he admitted

that he had thrown it from the truck’s window during the chase. The police recovered the gun

after Mr. Boggs led them back to the area where he had thrown it.

{¶4} Mr. Boggs was indicted on each of the following counts: (1) tampering with

evidence and an attendant firearm specification; (2) receiving stolen property and an attendant

firearm specification; and (3) improperly handling a firearm in a motor vehicle. The State later

dismissed the count for receiving stolen property, and Mr. Boggs went to trial on his remaining

counts. At the conclusion of his trial, a jury found him guilty, and the court sentenced him to a

total of one year and nine months in prison.

{¶5} Mr. Boggs now appeals from his convictions and raises three assignments of error

for review. Because his first and second assignments of error concern much of the same

testimony and evidence, this Court consolidates those assignments of error for ease of review.

II.

ASSIGNMENT OF ERROR NO. 1

THE TRIAL COURT ERRED AGAINST THE MANIFEST WEIGHT AND SUFFICIENCY OF THE EVIDENCE BY FINDING JAMIE L. BOGGS GUILTY OF TAMPERING WITH EVIDENCE WITH A GUN SPECIFICATION[.]

ASSIGNMENT OF ERROR NO. 2

THE JURY IN THE TRIAL COURT ERRED AGAINST THE MANIFEST WEIGHT AND SUFFICIENCY OF THE EVIDENCE WHEN IT FOUND THE DEFENDANT-APPELLANT, JAMIE L. BOGGS, GUILTY OF TAMPERING 3

WITH EVIDENCE AND IMPROPER HANDLING OF A FIREARM IN A MOTOR VEHICLE AND WITH A GUN SPECIFICATION.

{¶6} In his first and second assignments of error, Mr. Boggs argues that his convictions

for tampering with evidence and improperly handling a firearm in a motor vehicle are based on

insufficient evidence and are against the manifest weight of the evidence. For the following

reasons, this Court rejects his arguments.

{¶7} Initially, this Court notes that Mr. Boggs has addressed both the adequacy of the

State’s evidence and the persuasiveness of its evidence in a single analysis without attempting to

distinguish between the two concepts. Yet, “sufficiency and manifest weight are two separate,

legally distinct arguments.” State v. Vicente-Colon, 9th Dist. Lorain No. 09CA009705, 2010-

Ohio-6242, ¶ 20. The two concepts should be analyzed separately, lest this Court misinterpret an

argument or be forced to disregard it entirely for lack of analysis. See, e.g., State v. Messer, 9th

Dist. Summit No. 28750, 2018-Ohio-5117, ¶ 19. With that in mind, “this Court has attempted to

untangle [Mr. Boggs’] arguments in order to [separately] address them.” State v. Taylor, 9th

Dist. Summit No. 28746, 2018-Ohio-2921, ¶ 26.

Sufficiency of the Evidence

{¶8} “Whether a conviction is supported by sufficient evidence is a question of law

that this Court reviews de novo.” State v. Williams, 9th Dist. Summit No. 24731, 2009-Ohio-

6955, ¶ 18, citing State v. Thompkins, 78 Ohio St.3d 380, 386 (1997). The relevant inquiry is

whether the prosecution has met its burden of production by presenting sufficient evidence to

sustain a conviction. Thompkins at 390 (Cook, J., concurring). For purposes of a sufficiency

analysis, this Court must view the evidence in the light most favorable to the State. Jackson v.

Virginia, 443 U.S. 307, 319 (1979). We do not evaluate credibility, and we make all reasonable

inferences in favor of the State. State v. Jenks, 61 Ohio St.3d 259, 273 (1991). The evidence is 4

sufficient if it allows the trier of fact to reasonably conclude that the essential elements of the

crime were proven beyond a reasonable doubt. Id.

{¶9} Tampering with evidence occurs when a person, “knowing that an official

proceeding or investigation is in progress, or is about to be or likely to be instituted, * * *

[a]lter[s], destroy[s], conceal[s], or remove[s] any * * * thing, with purpose to impair its value or

availability as evidence in such proceeding or investigation * * * .” R.C. 2921.12(A)(1). “A

person acts purposely when it is [his] specific intention to cause a certain result * * *.” R.C.

2901.22(A). A person acts knowingly, regardless of purpose, when [he] is aware that [his]

conduct will probably cause a certain result or will probably be of a certain nature. A person has

knowledge of circumstances when [he] is aware that such circumstances probably exist. R.C.

2901.22(B). When examining whether a person knew an official investigation was “likely to be

instituted,” R.C. 2901.22(A), “[l]ikelihood is measured at the time of the act of alleged

tampering.” State v. Straley, 139 Ohio St.3d 339, 2014-Ohio-2139, ¶ 19. Nevertheless, “the

intent required by R.C. 2921.12(A)(1) can be inferred by the defendant’s words, actions, and

demeanor after a crime has been committed.” (Emphasis omitted.) State v. Price, 9th Dist.

Summit No. 28291, 2017-Ohio-4167, ¶ 18.

{¶10} A person commits the offense of improperly handling a firearm in a motor vehicle

if he “knowingly transport[s] or [has] a loaded firearm in a motor vehicle in such a manner that

the firearm is accessible to the operator or any passenger without leaving the vehicle.” R.C.

2923.16(B). The State may prove that a person knowingly transported or had a loaded firearm

by setting forth evidence that the person had actual or constructive possession of the firearm.

See State v. Coleman, 9th Dist. Summit Nos. 28640, 28641, 2018-Ohio-1923, ¶ 23-27. 5

{¶11} Officer Wise testified that his station received calls around 9:30 and 10:30 p.m. in

reference to gunshots having been fired in a residential area. He and other officers patrolled the

area following the 10:30 p.m.

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