State v. Henderson

2023 Ohio 586
CourtOhio Court of Appeals
DecidedMarch 1, 2023
DocketC-220216
StatusPublished

This text of 2023 Ohio 586 (State v. Henderson) 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. Henderson, 2023 Ohio 586 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Henderson, 2023-Ohio-586.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-220216 TRIAL NO. 22TRD-4824 Plaintiff-Appellee, :

VS. : O P I N I O N.

JEROME HENDERSON, :

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: March 1, 2023

Emily Smart Warner, City Solicitor, William T. Horsley, Chief Prosecuting Attorney, and Joshua Loya, Assistant Prosecuting Attorney, for Plaintiff-Appellee,

Frost Brown Todd LLC and Nathaniel L. Truitt, for Defendant-Appellant. OHIO FIRST DISTRICT COURT OF APPEALS

WINKLER, Judge.

{¶1} Defendant-appellant Jerome Henderson appeals his convictions for

driving with expired license plates, driving under suspension, and failing to stop after

an accident. Henderson argues that he was denied the effective assistance of trial

counsel because counsel failed to seek suppression of identification evidence. He

additionally challenges his convictions on sufficiency and weight-of-the-evidence

grounds. Because Henderson’s arguments lack merit, we affirm his convictions.

I. Background Facts and Procedure

{¶2} On the night of December 6, 2021, a driver operating a Chevy Suburban

escaped from an apartment parking lot where Cincinnati Police Officer Daniel Wuest

was investigating whether there were infractions related to the Suburban. During the

escape, the driver drove the Suburban in reverse to squeeze between Officer Wuest’s

police vehicle and parked cars. After striking several cars, the driver then pulled

forward to the end of the parking lot to turn around. Officer Wuest then exited from

his vehicle, ran up to the driver’s side window of the Suburban, and ordered the driver

to stop. The driver did not comply and instead made an escape by driving past the

officer. During the encounter, Officer Wuest was able to observe the driver’s face for

a “few moments” from “within one foot” away through the Suburban’s window that

was not tinted.

{¶3} The police found the Suburban abandoned nearby. The Suburban was

registered to a white female and the police found nothing in the Suburban tying

Henderson to the car.

{¶4} The following day, Officer Wuest was approached by members of the

police district’s Violent Crime Squad Unit (“VCS”) who had heard about the incident.

2 OHIO FIRST DISTRICT COURT OF APPEALS

They asked Officer Wuest to describe the driver, and Officer Wuest described him as a

“male black” wearing “a beanie and sweatshirt.” The VCS officers showed him two

photographs of Henderson taken by a VCS officer the previous day. Officer Wuest

noticed that the individual in the photograph and the black male he had seen driving

the Suburban shared the same “high cheek bones” and “facial hair” and, in one

photograph, Henderson was wearing the same outfit.

{¶5} Upon learning Henderson’s name from his fellow officers, Officer Wuest

charged Henderson with several offenses related to the operation of the Suburban. At

a bench trial, Officer Wuest, who is white, identified Henderson as the driver of the

Suburban with “[one] hundred percent” certainty. Defense counsel, who had not

moved to suppress Officer Wuest’s pretrial or in-court identification, cross-examined

the officer on the identification testimony and argued the identification was not

sufficient.

{¶6} Henderson, testifying in his defense, denied being present at the

apartment complex on the evening in question. He could not recall where he was, but

said he had no reason to be there on that date. However, he admitted that he was in a

relationship with a woman living there at the time and his cousin lived there.

Henderson further testified that he had never driven the Suburban involved in the

incident and he was familiar with the car because had seen a black man with a beard

and a white girlfriend driving it in the parking lot. Henderson denied having facial

hair on the date of the incident. He presented no evidence to corroborate his

testimony.

{¶7} The video captured from Officer Wuest’s vehicle dash-camera was

admitted into evidence. Upon consideration of all the evidence, the trial court found

3 OHIO FIRST DISTRICT COURT OF APPEALS

Henderson guilty of all offenses and sentenced him accordingly. The court specified

that it found the identification reliable though it involved a cross-racial identification.

Henderson now appeals, challenging his convictions in three assignments of error. II. Analysis

A. Ineffective-Assistance-of-Counsel Claim

{¶8} In his first assignment of error, Henderson argues that his convictions

should be reverse, and a new trial granted because he was denied the effective

assistance of trial counsel. To establish his claim, Henderson must demonstrate that

counsel’s performance fell beneath an objective standard of reasonableness and, but

for this deficient performance, a reasonable probability exists that the outcome would

differ. See Strickland v. Washington, 466 U.S. 668, 687-688, 104 S.Ct. 2052, 80

L.Ed.2d 674 (1984). Henderson must establish both prongs; once this court

determines a claim is deficient as to one prong, we need not address the other.

{¶9} Henderson specifies that counsel was ineffective when he did not seek

the suppression of Officer Wuest’s identification. He argues that counsel was not

motivated by trial strategy, the motion would have had a reasonable probability of

success, and the suppression of the identification testimony would have affected the

outcome of the case. We begin with the second prong, and we reject Henderson’s claim

because it is unlikely that the motion, if filed, would have been granted.

{¶10} Whether Officer Wuest’s identification should have been suppressed

entails a two-part inquiry. State v. Neal, 1st Dist. Hamilton No. C-140667, 2015-Ohio-

4705, ¶ 28, citing Perry v. New Hampshire, 565 U.S. 228, 238-239, 132 S.Ct. 716, 181

L.Ed.2d 694 (2012). The court must first determine whether the police used

“suggestive and unnecessary” identification procedures. Perry at 239, quoted in Neal

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at ¶ 28. If the identification procedures were suggestive, a then a court proceeds to a

second question: “ ‘whether under the totality of the circumstances, the identification

was reliable.’ ” Manson v. Brathwaite, 432 U.S. 98, 106, 97 S.Ct. 2243, 53 L.Ed.2d

140 (1977), quoting Neil v. Biggers, 409 U.S. 188, 199, 93 S.Ct. 375, 34 L.Ed.2d 401

(1972); Perry at 239-240; Neal at ¶ 28. This test applies both to pretrial and in-court

identifications. See, e.g., Neal at ¶ 26-31.

{¶11} The state concedes that showing a witness only one photograph is

generally deemed unnecessarily suggestive. See State v. Levingston, 1st Dist.

Hamilton No. C-090235, 2011-Ohio-1665, ¶ 9; State v. Dockery, 1st Dist. Hamilton

No. C-000316, 2002-Ohio-2309, ¶ 10. The state argues, however, that the

identification was admissible because based on the totality of the circumstances it was

reliable.

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Related

Neil v. Biggers
409 U.S. 188 (Supreme Court, 1972)
Manson v. Brathwaite
432 U.S. 98 (Supreme Court, 1977)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Dehass
227 N.E.2d 212 (Ohio Supreme Court, 1967)
State v. Jenks
574 N.E.2d 492 (Ohio Supreme Court, 1991)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
Perry v. New Hampshire
181 L. Ed. 2d 694 (Supreme Court, 2012)
State v. Messenger
2022 Ohio 4562 (Ohio Supreme Court, 2022)

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Bluebook (online)
2023 Ohio 586, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-henderson-ohioctapp-2023.