State v. Kitchen

2018 Ohio 5244
CourtOhio Court of Appeals
DecidedDecember 7, 2018
Docket18CA3840
StatusPublished
Cited by4 cases

This text of 2018 Ohio 5244 (State v. Kitchen) 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. Kitchen, 2018 Ohio 5244 (Ohio Ct. App. 2018).

Opinion

[Cite as State v. Kitchen, 2018-Ohio-5244.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT ROSS COUNTY

STATE OF OHIO, : Case No. 18CA3640

Plaintiff-Appellee, :

v. : DECISION AND JUDGMENT ENTRY MICHAEL KITCHEN, :

Defendant-Appellant. : RELEASED: 12/07/2018 APPEARANCES:

Michael L. Benson and Mark D. Tolles, II, Benson & Sesser, L.L.C., Chillicothe, Ohio, for appellant.

Matthew S. Schmidt, Ross County Prosecuting Attorney, and Pamela C. Wells, Ross County Assistant Prosecuting Attorney, Chillicothe, Ohio, for appellee. Harsha, J. {¶1} Following a declaration of a mistrial based on prosecutorial misconduct

and scheduling of a new jury trial, the Ross County Court of Common Pleas denied

Kitchen’s motions to dismiss the charge against him based on double-jeopardy and

constitutional speedy-trial claims.

{¶2} Because the common pleas court’s interlocutory entry denying his motion

to dismiss based on the constitutional right to a speedy trial does not constitute a final,

appealable order, we lack jurisdiction to address the merits of that assignment of error.

{¶3} We do have jurisdiction to address Kitchen’s assertion that the trial court

erred by denying his motion to dismiss based on double jeopardy. However, we reject it

because in general, there is no double-jeopardy bar to a retrial following a trial court’s

granting of a criminal defendant’s motion for a mistrial. And he has not established the

narrow exception to the general rule, which requires the request for a mistrial be Ross App. No. 18CA3640 2

precipitated by prosecutorial misconduct that was intentionally calculated to cause or

invite a mistrial.

{¶4} Here, the state committed prosecutorial misconduct by violating the trial

court’s order barring it from introducing any evidence of what Kitchen said in recorded

footage that was not disclosed to him before trial. However, there is no evidence that

the state intended to cause a mistrial by asking an officer one question regarding a

statement Kitchen made on the undisclosed footage. Specifically, (1) there was no

sequence of overreaching before the single question; (2) the state resisted Kitchen’s

request for a mistrial and appeared genuinely surprised that it had violated the court’s

order; and (3) the trial court concluded that although the state had committed

prosecutorial misconduct by eliciting testimony that violated its order, it was not the

state’s intent to cause the mistrial. We overrule Kitchen’s first assignment of error and

affirm the trial court’s judgment denying the double-jeopardy motion to dismiss.

I. FACTS

{¶5} The Ross County Grand Jury returned a secret indictment charging

Michael Kitchen with one count of sexual battery in violation of R.C. 2907.03, a third-

degree felony. The Ross County Sheriff’s Office arrested Kitchen and following his

arraignment the next day, he was released from custody upon posting a recognizance

bond. In its bill of particulars the state alleged that Kitchen engaged in vaginal

intercourse with Sara Howell, who was not his spouse, when he knew that she was

unaware that the act was being committed.

{¶6} In its opening statement at the jury trial, the state asserted Sara Howell

and her boyfriend let Kitchen, her high school friend, sleep over on a couch in their Ross App. No. 18CA3640 3

apartment in Chillicothe after going to eat. After her boyfriend left the next morning for

work, Howell awoke in her bedroom to discover that Kitchen was engaged in sex with

her without her consent. Kitchen finished the sexual act, left the room, and went back to

sleep on the couch in another room. After exchanging text messages with her father

and a friend, Howell contacted the police, made a report, and was administered a rape

kit. The testing determined that Kitchen’s DNA was found in semen in both Howell’s

vaginal and anal cavities.

{¶7} In Kitchen’s counsel’s opening statement, he contended that Kitchen and

Howell engaged in consensual sex, which had been initiated by Howell. He further

conceded that when Kitchen was awakened by three law enforcement officers

responding to Howell’s report of sexual battery, he lied that he did not have sex with

Howell because he was terrified and did not know what Howell had told them.

{¶8} The state’s first witness, Chillicothe Police Officer Shane Simmons,

testified that he and Officer Chip Campbell were dispatched to Howell’s apartment to

respond to a reported sexual assault. They talked to Howell and then entered the

apartment, where they observed Kitchen asleep on a couch. Then they contacted

Detective Twila Goble, who arrived and with Officer Campbell, they began questioning

Kitchen after advising him of his Miranda rights. Officer Simmons’s body camera was

activated during his interaction with both Howell and Kitchen. On cross-examination

Kitchen’s attorney played the body camera footage that had been provided to him by

the state in discovery. However, Officer Simmons testified that the footage shown was

not the end of his body camera footage. He indicated he had viewed other footage from

his body camera concerning the reported sexual battery. Ross App. No. 18CA3640 4

{¶9} Outside the presence of the jury Officer Simmons explained that there was

approximately 21 minutes of additional footage of Officer Campbell interrogating Kitchen

that the police had failed to disclose to the prosecutor because the old body cameras

would download footage to the server in multiple sections when it became too lengthy.

Kitchen moved for a mistrial based on the state’s failure to disclose this evidence in

discovery. The trial court overruled Kitchen’s motion, ordered the state to provide

Kitchen with a copy of the undisclosed body camera footage, and continued the case

until the next morning to permit Kitchen and his counsel to review the footage.

{¶10} The next morning after receiving the previously undisclosed recording of

Officer Simmons’s body camera footage, Kitchen’s attorney again asked for a mistrial,

generally asserting that “there would have been different statements and procedure and

strategy in this case had we been provided it.” He claimed that even if this additional

undisclosed footage was excluded, “it still doesn’t alleviate the issue that the jury knows

a video exists and is not going to be play[ed] and I’ve made statements, or

representations, that the video would be played * * *.” Significantly, the parties and the

trial court agreed that the state’s failure to provide this footage to the defense was

unintentional.

{¶11} The state noted Officer Simmons’s and Detective Gobles’s statements in a

Master Incident Report, which the state had provided to Kitchen and his counsel,

referenced several of Kitchen’s statements from the undisclosed body camera footage:

(1) Kitchen told the officers that he did not remember having sex with Sara; (2) Kitchen

told Officer Campbell he had a dream last night about having sex with his girlfriend; and Ross App. No. 18CA3640 5

(3) Kitchen stated that his girlfriend had told him that he had groped her in his sleep

before.

{¶12} The trial court denied Kitchen’s second motion for mistrial because: (1)

despite his concession that he initially told police he did not have sex with Howell,

Kitchen’s defense of consensual sex was consistent with what both the undisclosed and

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2018 Ohio 5244, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kitchen-ohioctapp-2018.