State v. Kinsey

2019 Ohio 4248
CourtOhio Court of Appeals
DecidedOctober 16, 2019
DocketC-180431
StatusPublished
Cited by2 cases

This text of 2019 Ohio 4248 (State v. Kinsey) 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. Kinsey, 2019 Ohio 4248 (Ohio Ct. App. 2019).

Opinion

[Cite as State v. Kinsey, 2019-Ohio-4248.]

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

STATE OF OHIO, : APPEAL NO. C-180431 TRIAL NO. B-1706565 Plaintiff-Appellant, :

vs. : O P I N I O N.

CHRISTOPHER KINSEY, :

Defendant-Appellee. :

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Reversed and Cause Remanded

Date of Judgment Entry on Appeal: October 16, 2019

Joseph T. Deters, Hamilton County Prosecuting Attorney, and Sean M. Donovan, Assistant Prosecuting Attorney, for Plaintiff-Appellant,

The Law Firm of John D. Hill, L.L.C., and John D. Hill, for Defendant-Appellee. OHIO FIRST DISTRICT COURT OF APPEALS

CROUSE, Judge.

{¶1} During a shootout involving over 20 people, with over 100 rounds

fired from an unknown number of firearms, an innocent bystander was shot and

injured. The state suspected that defendant-appellee Christopher Kinsey fired the

shot that injured the victim, but waited to charge him with felonious assault until it

received the ballistics report tying his rifle to the bullet that struck the victim. The

trial court granted Kinsey’s motion to dismiss the felonious-assault charge, holding

that his statutory speedy-trial rights had been violated.

{¶2} The state has appealed from the trial court’s dismissal of the felonious-

assault charge. In one assignment of error, the state argues that the trial court erred

in dismissing the indictment when it found that the ballistics report linking Kinsey to

the shooting was not new and additional evidence because not only had the state

possessed the bullet that hit the victim since the day of the shooting, it also had

probable cause prior to receiving the ballistics report to believe that Kinsey was the

one who had fired that bullet. Because we find the ballistics report to be new and

additional evidence, we reverse the trial court’s judgment granting the motion to

dismiss and remand the cause for further proceedings.

Factual Background

{¶3} On September 18, 2016, a confrontation between two groups over the

filming of a rap video led to a shootout in a residential neighborhood. The victim

was working in his yard and was hit by a stray bullet. Investigation led police to 931

Adams Street, one block south of where the shootout occurred. There, police found

Kinsey and another individual, both suffering from bullet wounds. Both were

2 OHIO FIRST DISTRICT COURT OF APPEALS

transported to the hospital. Police searched the house at 931 Adams Street and

found an M&P 15 rifle.

{¶4} Police also collected the bullet that struck the victim and sent it, along

with the rifle, to the coroner’s lab, which later sent it to the Bureau of Criminal

Investigation (“BCI”) for ballistics testing. That same day, police charged Kinsey

with having a weapon while under disability and receiving stolen property. Kinsey

pled guilty to those charges on November 17, 2016.

{¶5} Kinsey was immediately a suspect for the felonious assault, and was

interviewed as such, on September 18. Police tied the rifle to Kinsey because three

witnesses saw Kinsey with the rifle—one saw Kinsey retrieve the rifle from his car,

another saw Kinsey bring the rifle into 931 Adams Street, and a third saw Kinsey

actually fire the rifle. Police also located shell casings at the scene that matched the

type of ammunition for an M&P 15 rifle.

{¶6} On June 1, 2017, BCI released its ballistics report which confirmed that

the bullet that hit the victim was fired from Kinsey’s rifle. Kinsey was indicted for

felonious assault on July 24, 2017.

{¶7} Kinsey filed a motion to dismiss the indictment on the ground that his

speedy-trial rights under R.C. 2945.71 had been violated. After a hearing, the trial

court granted the motion to dismiss, holding that Kinsey’s speedy-trial rights had

been violated because more than 270 days had elapsed between the time Kinsey was

arrested on September 18, 2016, and indicted on July 24, 2017.

3 OHIO FIRST DISTRICT COURT OF APPEALS

Sole Assignment of Error

{¶8} The state argues that the trial court erred in dismissing the indictment

because the ballistics report represented new and additional evidence that Kinsey

was the one responsible for shooting the victim.

{¶9} Appellate review of a ruling on a motion to dismiss for a violation of

speedy-trial rights involves a mixed question of law and fact. State v. Terrell, 1st

Dist. Hamilton No. C-020194, 2003-Ohio-3044, ¶ 17. We review the trial court’s

factual findings to ensure they are supported by competent and credible evidence,

and review the court’s conclusions of law de novo. Id.

{¶10} The right to a speedy trial is guaranteed by the Sixth and Fourteenth

Amendments to the United States Constitution and Section 10, Article I of the Ohio

Constitution. To enforce the constitutional mandate, Ohio enacted R.C. 2945.71,

which designates specific time limits for bringing a defendant to trial. A defendant

charged with a felony, such as Kinsey, must be brought to trial within 270 days of

arrest. R.C. 2945.71(C)(2).

{¶11} The statutory speedy-trial provisions are coextensive with state and

federal constitutional speedy-trial provisions. The main distinction is that the

statutory right is specific and detailed, while the constitutional right requires a four-

factor analysis: the length of the delay, the reason for the delay, whether the

defendant requested a speedy trial, and whether he or she was prejudiced by the

delay. State v. Branch, 9 Ohio App.3d 160, 162, 458 N.E.2d 1287 (8th Dist.1983),

citing Barker v. Wingo, 407 U.S. 514, 530, 92 S.Ct. 2182, 33 L.Ed.2d 101 (1972).

Violation of the speedy-trial statute is not necessarily a violation of the constitutional

4 OHIO FIRST DISTRICT COURT OF APPEALS

speedy-trial right. City of Columbus v. Nappi, 5 Ohio St.2d 99, 100, 214 N.E.2d 83

(1966).

{¶12} The delay between Kinsey’s arrest on September 18, 2016, and his

indictment for felonious assault on July 24, 2017, is troubling, especially since very

little evidence was offered to explain the delay. Nevertheless, although determining

against whom the delay should be attributed would be relevant if we were analyzing a

constitutional violation of Kinsey’s speedy-trial rights, it is not relevant to our

analysis of whether the ballistics report represents new and additional evidence

which resets the 270-day speedy-trial clock under R.C. 2945.71(C)(2).

Adams, Baker, Cooney, and Burrell

{¶13} The Ohio Supreme Court in State v. Adams, 43 Ohio St.3d 67, 68, 538

N.E.2d 1025 (1989), held that

when new and additional charges arise from the same facts as did the

original charge and the state knew of such facts at the time of the initial

indictment, the time within which trial is to begin on the additional

charge is subject to the same statutory limitations period that is applied

to the original charge.

{¶14} In State v. Baker, 78 Ohio St.3d 108, 676 N.E.2d 883 (1997), the Ohio

Supreme Court clarified Adams, and announced the “new-and-additional-evidence”

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2019 Ohio 4248, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kinsey-ohioctapp-2019.