State v. Joseph

2025 Ohio 1204
CourtOhio Court of Appeals
DecidedApril 4, 2025
Docket2024-CA-34
StatusPublished

This text of 2025 Ohio 1204 (State v. Joseph) 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. Joseph, 2025 Ohio 1204 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Joseph, 2025-Ohio-1204.]

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

STATE OF OHIO : : Appellee : C.A. No. 2024-CA-34 : v. : Trial Court Case No. 23-CR-0567 : HERMANIO JOSEPH : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on April 4, 2025

R. JESSICA MANUNGO, Attorney for Appellant

ROBERT C. LOGSDON, Attorney for Appellee

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

EPLEY, P.J.

{¶ 1} Defendant-Appellant Hermanio Joseph appeals from his conviction in the

Clark County Court of Common Pleas of involuntary manslaughter. He was sentenced

to 9 to 13½ years in prison. For the reasons that follow, the judgment of the trial court will

be affirmed.

I. Facts and Procedural History -2-

{¶ 2} On the morning of August 22, 2023, Gene Collier was driving a school bus

full of children to their first day of school at Northwestern Elementary when a van driven

by Joseph, a Haitian immigrant who did not have a driver’s license, crossed the center

line into the bus’s lane. Collier attempted to guide his bus to the right to avoid a head-on

collision with the oncoming vehicle, but Joseph’s van kept its course and collided with the

bus. The impact caused the bus to veer off the road; it rolled and then came to rest on its

top in the ditch. Bystanders rushed to the scene to help the children. Many were injured,

some seriously, and A.C., who was ejected from the bus, died.

{¶ 3} Joseph was arrested and charged with one count of involuntary

manslaughter and one count of vehicular homicide. Additionally, an operating a motor

vehicle without a valid driver’s license specification was attached to the vehicular

homicide charge. Before the trial, Joseph filed a motion to change venue, citing “extensive

and ongoing pre-trial publicity and media saturation.” He argued that that the media

coverage of the event would make it “impossible to seat an impartial jury in [Clark]

County.” The court denied the motion but noted that it was amenable to reconsider if,

during voir dire, it became apparent that an impartial trial could not happen in Clark

County.

{¶ 4} The case proceeded to trial in the spring of 2024. Before testimony began,

the parties engaged in a detailed and thorough voir dire process; the inquiries from both

attorneys revolved around the potential jurors’ connections to the Northwestern

community and their feelings toward Haitians, a rapidly growing population in the

Springfield region of which Joseph was a member. After many potential jurors were -3-

excluded, the attorneys for Joseph and the State winnowed the pool to 12, with three

alternates. Defense counsel did not reassert the motion to change venue, and the trial

court did not sua sponte raise the issue either. The jury returned with guilty verdicts on

both counts after two days of testimony.

{¶ 5} At the disposition, the parties agreed that the involuntary manslaughter and

vehicular homicide counts would merge for sentencing, and the State elected to proceed

on involuntary manslaughter, as it was a first-degree felony. The trial court imposed a

prison term of 9 to 13½ years after considering statements from the victim’s family,

attorneys from both sides, and Joseph himself.

{¶ 6} Joseph appeals, raising three assignments of error.

II. Venue Change and Actual Bias of Jurors

{¶ 7} In his first and second assignments of error, Joseph presents connected

arguments that center on whether he had a fair trial in Clark County because of

unfavorable media coverage. He argues that the trial court should have granted his

pretrial motion for a change of venue, and then reconsidered the decision after voir dire,

because some jurors demonstrated bias. We will address these issues in a manner that

facilitates our analysis.

{¶ 8} Upon the motion of any party or upon its own motion, a trial court may transfer

a case to any court having jurisdiction of the subject matter outside the county in which

trial would otherwise be held, when it appears that a fair and impartial trial cannot be held

in the court in which the action is pending. Crim.R. 18(B). This motion must be made

within 35 days after arraignment or seven days before trial, whichever is earlier, or at such -4-

reasonable time later as the court may permit.

{¶ 9} Trial courts have a duty to protect defendants from prejudicial publicity that

renders the jury’s deliberations unfair. Sheppard v. Maxwell, 384 U.S. 333, 363 (1966).

“Even so, pretrial publicity – even pervasive, adverse publicity – ‘does not inevitably lead

to an unfair trial.’ ” State v. Grate, 2020-Ohio-5584, ¶ 50, quoting Nebraska Press Assn.

v. Stuart, 427 U.S. 539, 554 (1976). The Ohio Supreme Court has long held that “voir dire

examination provides the best test as to whether adverse publicity necessitates a change

of venue.” State v. Issa, 93 Ohio St.3d 49, 62 (2001); State v. Swiger, 5 Ohio St.2d 151,

164 (1966); State v. Bayless, 48 Ohio St.2d 73, 98 (1976), vacated on other grounds,

Bayless v. Ohio, 438 U.S. 911 (1978) (“a careful and searching voir dire provides the best

test of whether prejudicial pretrial publicity has prevented obtaining a fair and impartial

jury”). A defendant arguing that pretrial publicity has denied him or her a fair trial must

show that one or more jurors were actually biased. (Emphasis added.) State v. Treesh,

90 Ohio St.3d 460, 464 (2001).

{¶ 10} There are, however, rare cases in which pretrial publicity can be so

damaging that prejudice may be presumed without a showing of actual bias. Grate at

¶ 55. To prevail on a presumed prejudice claim, the defendant must make a “clear and

manifest showing . . . that pretrial publicity was so pervasive and prejudicial that an

attempt to seat a jury would be a vain act.” Id., quoting State v. Herring, 21 Ohio App.3d

18 (9th Dist. 1984), syllabus.

{¶ 11} The decision on a change of venue rests in the sound discretion of the trial

court. Treesh at 463. Absent a clear showing of an abuse of discretion, the decision of -5-

the trial court must remain. State v. Landrum, 53 Ohio St.3d 107, 116 (1990).

{¶ 12} Joseph’s first argument is that the alleged negative publicity against

Haitians in general, and his incident in particular, made it virtually impossible to obtain an

impartial jury in Clark County.

{¶ 13} The evidence in the record of pretrial publicity comes mainly in the form of

attorneys mentioning it a limited number of times during voir dire. Both attorneys spoke

about it once, generally, to the entire group.

Prosecutor: Okay. All right. There’s been a great deal of media attention on this

case. Who saw this or heard about this on TV, radio, somewhere?

(JURORS RESPOND AFFIRMATIVELY)

Prosecutor: [Juror 12], I’m going to pick on you again one more time. Would it

surprise you if I told you that the media is not always right?

Juror 12: Not at all.

Prosecutor: And would it surprise you if I told you sometimes law enforcement

and prosecutors withhold information from the media?

Prosecutor: Okay.

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Bluebook (online)
2025 Ohio 1204, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-joseph-ohioctapp-2025.