State v. Grim

2023 Ohio 4474
CourtOhio Court of Appeals
DecidedDecember 11, 2023
Docket8-23-01
StatusPublished
Cited by2 cases

This text of 2023 Ohio 4474 (State v. Grim) 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. Grim, 2023 Ohio 4474 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Grim, 2023-Ohio-4474.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT LOGAN COUNTY

STATE OF OHIO, CASE NO. 8-23-01

PLAINTIFF-APPELLEE,

v.

ETHAN C. GRIM, OPINION

DEFENDANT-APPELLANT.

Appeal from Logan County Common Pleas Court Trial Court No. CR 21 07 0172

Judgment Affirmed

Date of Decision: December 11, 2023

APPEARANCES:

William T. Cramer for Appellant

Eric C. Stewart for Appellee Case No. 8-23-01

WALDICK, J.

{¶1} Defendant-appellant, Ethan Grim (“Grim”), brings this appeal from the

January 25, 2023, judgment of the Logan County Common Pleas Court sentencing

him to prison after Grim was convicted by a jury of two counts of Complicity to

Murder, Complicity to Aggravated Burglary, Complicity to Aggravated Robbery,

and two counts of Complicity to Felonious Assault.1 On appeal, Grim argues that

he was denied Due Process and his rights under the Confrontation Clause when a

detective was permitted to testify regarding statements made by Grim’s

codefendants at Grim’s juvenile probable cause hearing. Grim also argues that his

convictions were against the manifest weight of the evidence, that certain evidence

was improperly admitted at his trial, and that the trial court improperly considered

evidence outside the record when sentencing Grim. For the reasons that follow, we

affirm the judgment of the trial court.

Background

{¶2} On November 27th, 2019, four individuals conspired to steal from a

drug dealer in Bellefontaine. Three of the four individuals unlawfully entered the

drug dealer’s residence while the fourth individual waited in the car outside. During

the home invasion, multiple residents were assaulted and two residents were shot in

the head and killed.

1 In addition, the jury convicted Grim of Complicity to Kidnapping, but that charge was merged for purposes of sentencing. Further, all charges contained firearm specifications.

-2- Case No. 8-23-01

{¶3} One of the home-invaders, Elijah Barrett (“Barrett”), was shot in the leg

during the incident and he was taken to a hospital in Urbana. Barrett ultimately

confessed and named his three accomplices: Ethan Grim (“Grim”), Austin Allen

(“Allen”), and Josia Bush (“Bush”). Allen, the driver who waited outside during the

home invasion, also confessed to his role and implicated Grim, Bush, and Barrett as

well.

{¶4} Grim was less than a month shy of his 18th birthday when the crimes

were committed. Barrett and Bush were also juveniles but Allen, the driver, was an

adult.

{¶5} A delinquency complaint was filed against Grim charging him with,

inter alia, Complicity to Aggravated Burglary and Complicity to Murder. On

December 30, 2019, the State filed a motion to relinquish jurisdiction over Grim

seeking a discretionary bindover pursuant to R.C. 2152.12(B).

{¶6} Over objection from Grim, the juvenile court held a joint probable cause

hearing for all three juveniles. The juvenile court ultimately determined that there

was probable cause to believe that Grim and the two others committed the charged

acts.

{¶7} On June 1, 2021, an amenability hearing was held on the State’s motion

to relinquish jurisdiction.2 After hearing the testimony presented and reviewing the

2 Prior to the hearing, a social history investigation and a forensic psychological evaluation of Grim were conducted.

-3- Case No. 8-23-01

submitted evaluation, the juvenile court determined that the factors in favor of

transfer outweighed the factors against transfer, that Grim was not amenable to

rehabilitation in the juvenile system, and that the safety of the community required

that Grim be subject to adult sanctions. The juvenile court granted the State’s motion

to relinquish jurisdiction and bound Grim over to the Logan County Common Pleas

Court.

{¶8} On July 13, 2021, Grim was indicted for Complicity to Aggravated

Burglary in violation of R.C. 2911.11(A)(1) and R.C. 2923.03, a first degree felony

(Count 1), Complicity to Aggravated Robbery in violation of R.C. 2911.01(A)(3)

and R.C. 2923.03, a first degree felony (Count 2), Complicity to Kidnapping in

violation of R.C. 2905.01(A)(2) and R.C. 2923.02, a first degree felony (Count 3),

two counts of Complicity to Felonious Assault in violation of R.C. 2903.11(A)(2)

and R.C. 2923.03, both second degree felonies (Counts 4 and 5), and two counts of

Complicity to Murder in violation of R.C. 2903.02(B) and R.C. 2923.03, both

unclassified felonies (Counts 6 and 7). All seven counts in the indictment contained

three-year firearm specifications pursuant to R.C. 2941.145(A). Grim pled not

guilty to the charges.

{¶9} Grim proceeded to a jury trial from January 9-12, 2023. At the

conclusion of the trial, the jury found Grim guilty of all counts in the indictment and

specifications. On January 25, 2023, Grim was sentenced to serve an aggregate,

indefinite prison term of 50 years to life, with parole eligibility after 25 years. Grim

-4- Case No. 8-23-01

now appeals his convictions and sentence, asserting the following assignments of

error for our review.

First Assignment of Error

Appellant’s rights to due process under the state and federal constitutions were violated when the juvenile court denied appellant the ability to confront and cross-examine his accusers.

Second Assignment of Error

Appellant’s convictions were not supported by the weight of the evidence.

Third Assignment of Error

The trial court abused its discretion in admitting hearsay evidence from a non-testifying co-defendant.

Fourth Assignment of Error

The trial court abused its discretion in admitting an out-of-court statement to explain the conduct of an accomplice.

Fifth Assignment of Error

The trial court erred by crafting a sentence based on testimony from a codefendant’s separate trial that was not in the record in this case.

{¶10} In his first assignment of error, Grim argues that his Due Process

rights, and his rights under the Confrontation Clause, were violated when one of the

State’s witnesses was permitted to testify regarding statements elicited from Grim’s

codefendants at the probable cause hearing in juvenile court.

-5- Case No. 8-23-01

Standard of Review

{¶11} Generally, the admission of evidence lies within the broad discretion

of the trial court. State v. Conway, 109 Ohio St.3d 412, 2006-Ohio-2815, ¶ 62.

However, we conduct a de novo review of hearsay evidentiary rulings that implicate

the confrontation clause. State v. McKelton, 148 Ohio St.3d 261, 2016-Ohio-5735,

¶ 97.

Analysis

{¶12} In determining the State’s motion for discretionary bindover in this

matter, the juvenile court held a joint probable cause hearing for Grim, Bush, and

Barrett. At the hearing, the State presented the testimony of eight witnesses, one of

whom was a detective with the Bellefontaine Police Department. The detective

testified to statements made to him by Barrett and Allen that implicated Grim in the

crimes.

{¶13} Objections were made to the detective relaying out-of-court

statements made by Barrett and Allen. Attorneys for the juveniles argued that since

Barrett and Allen were not testifying, the evidence was in violation of the

Confrontation Clause. The State responded that in a probable cause hearing, rather

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2026 Ohio 544 (Ohio Court of Appeals, 2026)
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Bluebook (online)
2023 Ohio 4474, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-grim-ohioctapp-2023.