State v. Fowler

2024 Ohio 361
CourtOhio Court of Appeals
DecidedFebruary 2, 2024
Docket2022-CA-28
StatusPublished

This text of 2024 Ohio 361 (State v. Fowler) 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. Fowler, 2024 Ohio 361 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Fowler, 2024-Ohio-361.]

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

STATE OF OHIO : : Appellee : C.A. No. 2022-CA-28 : v. : Trial Court Case No. 22CR113 : MICHAEL O. FOWLER, JR. : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on February 2, 2024

CARLO C. MCGINNIS, Attorney for Appellant

PAUL M. WATKINS, Attorney for Appellee

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

WELBAUM, J.

{¶ 1} Defendant-appellant, Michael O. Fowler, Jr., appeals from his conviction in

the Miami County Court of Common Pleas after a jury found him guilty of unlawful sexual

conduct with a minor. In support of his appeal, Fowler claims that the trial court erred by

failing to suppress incriminating statements that he had made to detectives during an

interview. Fowler claims that his statements should have been suppressed because he -2-

did not knowingly, intelligently, and voluntarily waive his Miranda rights and because his

statements were rendered involuntary by impermissible, coercive police conduct.

Fowler also claims that the trial court erred by admitting certain records from Google at

trial. According to Fowler, the Google records were not properly authenticated and

violated his constitutional right of confrontation. For the reasons outlined below, we find

no merit to Fowler’s claims and will affirm the judgment of the trial court.

Facts and Course of Proceedings

{¶ 2} On April 1, 2022, a Miami County grand jury returned an indictment charging

Fowler with one third-degree-felony count of unlawful sexual conduct with a minor in

violation of R.C. 2907.04(A)/(B)(3), and a forfeiture specification for Fowler’s vehicle.

The charge and specification arose from allegations that Fowler had the victim, who was

13 years old, perform fellatio on him in his vehicle in exchange for providing the victim

with a vape pen.

{¶ 3} Fowler pled not guilty to the indicted charge and specification and then filed

a motion to suppress statements that he had made during an interview with investigating

detectives. In support of his motion to suppress, Fowler claimed that he had not

knowingly, intelligently, and voluntarily waived his Miranda rights. Fowler also claimed

that his statements should have been suppressed because they were the product of

impermissible, coercive police conduct.

{¶ 4} On July 7, 2022, the trial court held a hearing on Fowler’s motion to suppress.

During the hearing, the State presented testimony from one of the detectives who -3-

interviewed Fowler, i.e., Detective Steve Hickey of the Miami County Sheriff’s Office.

The State also presented audio and video recordings of Det. Hickey’s interactions with

Fowler. The evidence presented at the suppression hearing established that on March

7, 2022, Det. Hickey and Det. Jason Moore traveled to the Adult Parole Authority (“APA”)

office in Dayton, Ohio, to meet with Fowler after his regular office visit with his parole

officer. The detectives’ discussion with Fowler at the APA office was audio recorded and

admitted into evidence at the suppression hearing as State’s Exhibit 1.

{¶ 5} State’s Exhibit 1 established that the detectives introduced themselves to

Fowler and advised that they had some questions for him regarding an investigation.

Det. Hickey told Fowler that he and Det. Moore would like to talk to him at the Miami

County Sheriff’s Office in Troy and asked if he was willing to go there with them. When

Fowler asked whether he had a choice in the matter, Det. Hickey answered no and said

that, either way, they would be taking him to the sheriff’s office. Hickey did, however,

offer to have a discussion with Fowler at the APA office, but Fowler decided to wait and

talk to the detectives at the sheriff’s office since they were going to take him there anyway.

{¶ 6} Shortly thereafter, Det. Hickey read Fowler his Miranda rights. In doing so,

Det. Hickey asked Fowler if he understood each of the rights that were read to him. In

response, Fowler verbally affirmed his understanding of the rights. No waiver card or

other written materials were provided to Fowler during the Miranda advisement.

{¶ 7} The detectives’ discussion with Fowler at the APA office lasted for

approximately 10 minutes. Thereafter, the detectives placed Fowler in handcuffs and

transported him to the Miami County Sheriff’s Office in Troy. The detectives did not ask -4-

Fowler any questions about the investigation prior to arriving at the sheriff’s office.

Fowler’s transportation to the sheriff’s office took approximately 45 minutes. While at the

sheriff’s office, the detectives began to video record their interaction with Fowler. The

video recording was continuous with the audio recording that was initiated at the APA

office in Dayton. Accordingly, there was no break in the recording between the time

Fowler was taken from Dayton to Troy. The video recording was admitted into evidence

at the suppression hearing as State’s Exhibit 2.

{¶ 8} State’s Exhibit 2 established that, before interviewing Fowler, Det. Hickey

told Fowler: “Just a reminder, you are still under Miranda rights. I read you your Miranda

rights. You understand all that?” In response, Fowler shook his head affirmatively and

said: “Right.” Det. Hickey then began the interview. During the interview, Fowler did

not deny that he had met with the victim and that he had provided the victim with a vape

pen. Although Fowler initially denied that the victim had performed fellatio on him in

exchange for the vape pen, after further questioning, and after the detectives stressed

the importance of honesty and cooperation, Fowler eventually admitted that the victim

had put her lips on his penis.

{¶ 9} After considering the testimony and evidence presented at the suppression

hearing, the trial court overruled Fowler’s motion to suppress. The matter thereafter

proceeded to a jury trial. During trial, the State presented the testimony of multiple

witnesses, including Detective Sergeant Todd Cooper of the Miami County Sheriff’s

Office.

{¶ 10} Det. Cooper’s testimony established that he had applied for a geofence -5-

warrant through Google in an effort to identify a suspect. Det. Cooper explained that

Google is able to use the Global Positioning System (“GPS”) to track any working cellular

device that has the Google application downloaded onto it. In applying for the geofence

warrant, Det. Cooper provided Google with the coordinates of a fifteen-meter radius

around the victim’s residential driveway. Det. Cooper requested Google to track any

cellular devices that had entered that radius during a specific timeframe in which the victim

had met with Fowler.

{¶ 11} In response to the geofence warrant, Google sent Det. Cooper a letter, a

signed Certificate of Authenticity, and the requested information. See State’s Trial

Exhibit 3. The information provided by Google established that there had been one

cellular device detected in the radius provided by Det. Cooper during the timeframe in

question. After learning about this device, Det. Cooper sent a second request for Google

to provide him with the account information associated with the device.

{¶ 12} In response to Det. Cooper’s second request, Google once again sent a

letter, a signed Certificate of Authenticity, and the requested information. See State’s

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Prichard
2026 Ohio 56 (Ohio Court of Appeals, 2026)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 361, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-fowler-ohioctapp-2024.