State v. Huffman

2024 Ohio 889, 237 N.E.3d 901
CourtOhio Court of Appeals
DecidedMarch 11, 2024
Docket2023-L-057
StatusPublished
Cited by5 cases

This text of 2024 Ohio 889 (State v. Huffman) 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. Huffman, 2024 Ohio 889, 237 N.E.3d 901 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Huffman, 2024-Ohio-889.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY

STATE OF OHIO, CASE NO. 2023-L-057 CITY OF EASTLAKE,

Plaintiff-Appellee, Criminal Appeal from the Willoughby Municipal Court - vs -

MICHAEL HUFFMAN, SR., Trial Court No. 2022 CRB 01795

Defendant-Appellant.

OPINION

Decided: March 11, 2024 Judgment: Affirmed

Jackie O’Donnell, City of Eastlake Prosecuting Attorney, 35150 Lakeshore Blvd., Eastlake, OH 44095 (For Plaintiff-Appellee).

Hector G. Martinez, Jr., and Richard J. Perez, 4230 State Route 306, Suite 240, Willoughby, OH 44094 (For Defendant-Appellant).

JOHN J. EKLUND, J.

{¶1} Appellant, Michael Huffman, Sr., appeals his conviction of Sexual

Imposition, a third-degree misdemeanor in violation of R.C. 2907.06(A)(1). For the

following reasons, we affirm the judgment of the Willoughby Municipal Court.

{¶2} On appeal, Appellant raises five assignments of error: (1) The State failed

to preserve and produce Appellant’s recorded interview with the Eastlake Police

Department; (2) the trial court erred in not imposing a sanction on the State for failing to

produce evidence; (3) the trial court erred in denying Appellant’s Crim.R. 29 motion for acquittal; (4) Appellant’s conviction was against the manifest weight of the evidence; (5)

the trial court gave the jury an incorrect instruction on the definition of “purposely.”

{¶3} After a review of the record and applicable case law, Appellant’s

assignments of error are without merit. Appellant’s video recorded interview was only

potentially useful, and the detective did not act in bad faith in failing to preserve it. The

trial court did not err when it denied Appellant’s request to impose sanctions for failing to

preserve the recording because Appellant did not demonstrate that the failure to preserve

was willful, that foreknowledge of the recording’s loss would have benefited him in the

preparation of a defense, and that he was prejudiced. Appellant’s conviction was not

against the manifest weight of the evidence because a reasonable jury could find that

Appellant had sexual contact with the victim knowing that the sexual contact was

offensive to her. Because Appellant's conviction was not against the manifest weight of

the evidence, there was sufficient evidence to support his conviction. Finally, the trial

court did not abuse its discretion in instructing the jury on the definition of “purposely”

because “purpose” is not included in R.C. 2907.06(A)(1) and the court is not required to

give jury instructions that are repetitive or may confuse the jury.

{¶4} On August 11, 2022, a complaint was filed against Appellant for committing

Sexual Imposition. Appellant pled not guilty.

{¶5} On February 22, 2023, Appellant moved to dismiss, asserting that his due

process rights had been violated because the State failed to preserve and produce his

recorded interview with Detective Fawcett from the Eastlake Police Department.

{¶6} Before trial commenced, the court held an oral hearing on Appellant’s

motion. Detective Fawcett testified that she conducted an interview with Appellant on

Case No. 2023-L-057 July 21, 2022 in relation to the incident leading to his conviction. She testified that

typically, the detectives are required to file a request to preserve recorded interviews.

But, she did not request to preserve Appellant’s interview. Detective Fawcett said that

her failure to request to preserve the recorded interview “was an honest mistake. I had

multiple interviews that day, which is no excuse. And I was dispatched to another call for

service minutes later. Unfortunately, it was an inadvertent human error.” Detective

Fawcett testified that upon realizing that the video had not been preserved, the police

department attempted to recover the recording, but was not successful. She stated that

during his interview, Appellant denied the allegations against him. Detective Fawcett also

wrote a report following the interview as to what Appellant told her.

{¶7} The court denied Appellant’s motion to dismiss. It found that the recorded

interview was not materially exculpatory, but rather was potentially useful to the defense.

The court also found that the State did not act in bad faith in failing to preserve the

recorded interview and found “the testimony of the detective credible in that as she was

called away, failed to preserve the recording. So the motion to dismiss is denied.”

{¶8} On February 27, 2023, a jury trial commenced. The victim, Hilary Quellos,

testified that on July 19, 2022 at approximately 7:00 p.m., she visited the Offshore Bar

and Grille to see her boyfriend, Theodore Shepard, who was tending bar. The victim

occasionally worked at the bar, but also visited the bar approximately “once a week” for

social reasons. When she entered the bar, she greeted Appellant and his friend, Kirk

Heintz, by hugging them and kissing them on the cheek. She knew Appellant and Mr.

Heintz as acquaintances because she had tended bar at a different bar in the area years

prior to the incident. The victim interacted with Appellant throughout the night and walked

Case No. 2023-L-057 over to say goodbye to him before leaving. She testified that during this interaction,

Appellant “grabbed me by my ear, and he like kind of pulled me in to his chest. * * * Then

he touched my butt. Like the first time was just a touch.” She described it as

“uncomfortable” and “terrible” and she “told him to stop, knock it off.” She claimed that

Appellant then touched her buttocks again. The victim described the second touching as

“painful” because he placed his hands lower and “he put his hand where it was actually

his fingers were like on top of my [public region] pushing hard, it hurt.” She reacted by

pushing his hands away from her body. Mr. Heintz then commented that the victim’s

“[breasts] had gotten smaller, they were gone.” Following this statement, Appellant

“grabbed” her breasts and told her that she was “hot.” The victim “awkwardly” “giggled”

and walked away.

{¶9} The State offered, as an exhibit, the bar’s video surveillance of the incident.

The victim pointed to the moment in the video where Appellant was “touching my ear,

grabbing me into his chest, grabbing my behind the first time, grabbing my behind the

second time, where he puts it further in, and him touching my breast.”

{¶10} Appellant left the bar shortly after the incident. The victim stayed at the bar

to tell her friend Carolyn Karnak, who was tending bar, about what had happened because

she was upset. Mr. Shepard had ended his shift before the incident occurred and was

already home when the victim returned to her residence that evening. She told him that

Appellant had “grabbed” her pubic region. She then called the police department to report

the incident. Two peace officers arrived. Officer Otallah testified that the victim was

“upset” and “crying” when they arrived. The victim told the officers that Appellant had

Case No. 2023-L-057 touched her buttocks, but did not mention him touching her breasts. A police investigation

began.

{¶11} Detective Fawcett testified at trial. Before her testimony, defense counsel

objected to Detective Fawcett testifying and moved the court to impose sanctions on the

State for failing to preserve the recorded interview. The court denied the motion,

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 889, 237 N.E.3d 901, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-huffman-ohioctapp-2024.