State v. Fader

2024 Ohio 4921, 254 N.E.3d 261
Ohio Court of Appeals·Decided October 11, 2024·No. 2024-CA-1·Published·Cited by 1 cases

Opinion

[Cite as State v. Fader, 2024-Ohio-4921.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT DARKE COUNTY

STATE OF OHIO : : Appellee : C.A. No. 2024-CA-1 : v. : Trial Court Case No. 23-CRB-001-0418 : RICK T. FADER : (Criminal Appeal from Municipal Court) : Appellant : :

...........

OPINION

Rendered on October 11, 2024

RICHARD L. KAPLAN, Attorney for Appellant

CHANCE O. COX, Attorney for Appellee

.............

EPLEY, P.J.

{¶ 1} Defendant-Appellant Rick T. Fader appeals from his conviction in the Darke

County Municipal Court after a jury found him guilty of voyeurism. For the reasons that

follow, the judgment of the trial court will be reversed, and the case will be remanded for -2-

further proceedings.

I. Facts and Procedural History

{¶ 2} B.F. and his longtime girlfriend, B.C., bought a house on East Main Street

in Greenville in June 2023. They wanted a television installed on the wall in the master

bedroom and asked Fader (who had worked as a handyman) to install an electrical outlet

and a wall mount for the television. The plan was for the outlet to be hidden by the

television so the wires were not visible. On July 1, while neither B.F. nor B.C. was home,

Fader installed the outlet. A few days later, this time when B.F. was home, Fader returned

to do the wall mount and the television. The outlet and television were facing the bed and

were about 5½ feet up on the wall. Once the television was installed, however, it was

discovered that the outlet was several inches below the bottom edge of the screen.

{¶ 3} On July 8, 2023, while he was inspecting the outlet’s built-in USB ports, B.F.

discovered a tiny camera built into a hole in the center of outlet. He testified that he

“freaked out a little bit,” went to his brother’s house to cool down, and then came back

home to take the outlet out of the wall. Once removed, he noticed the outlet had a circuit

board on the back; further investigation revealed a secure digital (SD) memory card.

{¶ 4} B.F. removed the SD card from the outlet and inserted it into his computer.

The card contained no videos but many, many photos. The camera appeared to be taking

pictures every 5 to 10 seconds, which were sorted into folders by date. B.F. was

particularly concerned about pictures from July 6, a day he and B.C. had sex, but the

folder from that date was missing.

{¶ 5} On July 9, B.F. took the outlet and SD card to Greenville police detective -3-

Dale Dickman. Detective Dickman used department resources to examine the SD card.

He found hundreds of images from the bedroom; they were time-stamped and in files by

date. Among the hundreds were “private” ones, showing a naked female and the naked

buttocks of a male.

{¶ 6} Based on the ensuing investigation, Fader was charged by criminal complaint

with voyeurism, in violation of R.C. 2907.08(B), a second-degree misdemeanor. The case

proceeded to a jury trial on January 19, 2024. The jury heard testimony from B.F., B.C.,

Detective Dickman, and Kerry Smoot, the chief investigator for the Montgomery County

Prosecutor’s Office, who helped analyze the outlet, SD card, and pictures.

{¶ 7} After deliberations, the jury found Fader guilty. He was sentenced to a jail

term of 89 days and classified as a Tier I sex offender. He has filed a timely appeal that

raises four assignments of error.

II. Jury Instructions

{¶ 8} In his first assignment of error, Fader argues that the trial court’s failure to

instruct the jury on the definition of “reasonable doubt” was reversible error and was a

violation of the Fifth and Sixth Amendments to the United States Constitution.

{¶ 9} What the factfinder must determine to reach a guilty verdict is prescribed by

the Due Process Clause. Sullivan v. Louisiana, 508 U.S. 275, 277 (1993). The

prosecution bears the burden of proving all elements of the offense charged, see, e.g.,

Patterson v. New York, 432 U.S. 197, 210 (1977); Leland v. Oregon, 343 U.S. 790, 795

(1952), and it must persuade the factfinder “beyond a reasonable doubt” of the facts

necessary to establish each element. See In re Winship, 397 U.S. 358, 364 (1970); Cool -4-

v. United States, 409 U.S. 100, 104 (1972). “In other words, the jury verdict required by

the Sixth Amendment is a jury verdict of guilty beyond a reasonable doubt.” Sullivan at

278. This is true federally and in Ohio.

{¶ 10} R.C. 2901.05(A) states that “[e]very person accused of an offense is

presumed innocent until proven guilty beyond a reasonable doubt, and the burden of

proof for all elements of the offense is upon the prosecution.” That a person is innocent

until proven guilty beyond a reasonable doubt is fundamental and a well-known phrase in

our vernacular. The meaning of “reasonable doubt” is much less understood, however,

which is why the statute demands it be defined for the jury.

{¶ 11} R.C. 2901.05(C) requires that, as part of its charge to the jury in a criminal

case, “the court shall read the definitions of ‘reasonable doubt’ and ‘proof beyond a

reasonable doubt[.]’ ” (Emphasis added.) The terms are defined as:

“Reasonable doubt” is present when the jurors, after they have carefully

considered and compared all the evidence, cannot say they are firmly

convinced of the truth of the charge. It is a doubt based on reason and

common sense. Reasonable doubt is not mere possible doubt, because

everything relating to human affairs or depending on moral evidence is open

to some possible or imaginary doubt. “Proof beyond a reasonable doubt” is

proof of such character that an ordinary person would be willing to rely and

act upon it in the most important of the person’s own affairs.

R.C. 2901.05(E).

{¶ 12} At the conclusion of testimony, the trial court gave the jury its instructions. -5-

It explained the elements of the crime of voyeurism and, as pertinent to this case, the

court noted that “Rick Fader must be presumed innocent until his guilt is proven beyond

a reasonable doubt.” Trial Tr. at 259. It further told the jury that Fader “must be acquitted

or found not guilty unless the prosecution produces evidence that convinces you beyond

a reasonable doubt of every essential element of the offense charged.” Id. Although the

court mentioned the concept of “reasonable doubt,” it failed to explain what the term

actually means.

{¶ 13} Fader argues that not explaining the definition of “reasonable doubt” to the

jury was structural error, necessitating reversal. Structural errors “affect the very

framework of the trial, permeating the conduct of the trial from beginning to end, to the

point that the trial cannot be a reliable means of determining guilt or innocence.” State v.

Miller, 2009-Ohio-4607, ¶ 16 (2d Dist.). Structural error analysis is for “constitutional

deprivations” rather than an error in the trial process itself. State v. Lazzerini, 2021-Ohio-

1998, ¶ 16 (5th Dist.). If the State can demonstrate “beyond a reasonable doubt that the

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State v. Fader, 2024 Ohio 4921, 254 N.E.3d 261 (Ohio Ct. App. 2024).

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