State v. Letner

2023 Ohio 610, 209 N.E.3d 925
CourtOhio Court of Appeals
DecidedMarch 2, 2023
Docket111552
StatusPublished
Cited by2 cases

This text of 2023 Ohio 610 (State v. Letner) 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. Letner, 2023 Ohio 610, 209 N.E.3d 925 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Letner, 2023-Ohio-610.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 111552 v. :

MATTHEW W. LETNER, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: March 2, 2023

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-21-664489-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Michael Lisk, Assistant Prosecuting Attorney, for appellee.

Cullen Sweeney, Cuyahoga County Public Defender, and Erika B. Cunliffe, Assistant Public Defender, for appellant.

ANITA LASTER MAYS, A.J.:

Defendant-appellant Matthew W. Letner (“Letner”) appeals his jury

trial conviction for promoting prostitution in violation of R.C. 2907.22(A)(2). We

affirm the trial court’s judgment. I. Facts and Procedural History

On October 28, 2021, Letner was indicted on the following counts:

(1) rape, first-degree felony, R.C. 2907.02(A)(2); (2) kidnapping, a first-degree

felony, with a sexual motivation specification, R.C. 2905.01(A)(4) and 2941.147(A)

respectively; (3) domestic violence, first-degree misdemeanor, R.C. 2919.25(A);

(4) gross sexual imposition, fourth-degree felony, R.C. 2907.05(A)(1); (5) domestic

violence, first-degree misdemeanor, R.C. 2919.25(A); (6) compelling prostitution, a

third-degree felony, R.C. 2907.21(A)(1); and (7) promoting prostitution, fourth-

degree felony, R.C. 2907.022(A)(2).

The charges arose from events that transpired between Letner and

his former girlfriend, Jane Doe. Letner pleaded not guilty, and the case proceeded

to a jury trial on April 26, 2022. Prior to jury voir dire, Letner objected to the trial

court’s decision to allow Letner to proceed with trial wearing his jail uniform but

without restraints.

The state called four witnesses. Doe testified that she and Letner had

been acquaintances for five or six years and began to date about January 2021. At

the time, Doe was allegedly in an abusive relationship with her former boyfriend,

Victor Novak (“Novak”), who died in October 2020. Doe was involved with

prostitution and drugs when she met Letner who was aware of her activities. Letner

was employed and encouraged Doe to improve her lifestyle. Doe moved in with

Letner and the two stayed at Airbnbs and hotels while Doe continued her prostitution activities with Letner’s knowledge so they could build financial stability.

Doe also continued to use drugs.

Letner told her that she should increase her prices and assisted her

with pricing and logistics. About one month after their initial agreement to work

toward economic stability, Letner stopped working and Doe became the sole income

source. Letner focused on managing Doe’s activities such as running ads, text

messaging and setting prostitution appointments. In support of the rape count, Doe

described an encounter that involved Letner allegedly sexually assaulting her. Doe

locked herself in the bathroom until police arrived in the morning.

Kevin North (“North”) testified about his friendship of several years

with Doe and more recent acquaintance with Letner. North met Letner in August

2021 at Doe’s invitation. North arrived at the hotel where Doe and Letner resided

at the time to find Letner focused on a cell phone placing ads and texting to make

appointments for Doe’s prostitution activities. North confirmed that Doe called

North when Doe was hiding from Letner in the bathroom. North called a police

friend who said an officer would perform a wellness check.

Cleveland Police Department (“CPD”) officer Ricardo Holt-Santiago

(“Officer Holt-Santiago”) responded to the scene at 9:00 a.m. in response to a

“check-well” call received at 8:45 a.m. Officer Holt-Santiago was wearing a body

camera. Letner answered the door. Doe emerged about ten minutes later and

appeared to be afraid. Officer Holt-Santiago narrated the recorded events for the jury, discussed his interaction with Doe and said that two cell phones were removed

from the scene.

CPD detective Durst (“Det. Durst”) with the sex crimes unit also

worked for the regional human trafficking task force. Det. Durst met with Doe, took

photographs, and telephonically interviewed North. Det. Durst testified that three

cell phones were removed from the scene. He was aware that one phone belonged

to Doe and assumed one of the others belonged to Letner. Det. Durst did not unload

the contents of the two phones that potentially contained evidence of the

prostitution activities including payments.

The state dismissed the Count 5 domestic violence charge with

prejudice and rested. Letner’s original and renewed motions for judgment of

acquittal under Crim.R. 29 were denied.

Letner was acquitted of all counts except Count 7 for promoting

prostitution under R.C. 2907.22(A)(2). Letner appeals.

II. Assignments of error

Letner assigns the following as error:

I. By forcing Matthew Letner to proceed to jury trial wearing his jail clothes, notwithstanding his objection to doing so, the trial court violated Letner’s state and federal constitutional rights to due process, a fair trial, and the presumption of innocence.

II. Matthew Letner’s conviction for promoting prostitution violates his right to due process as protected by the Fourteenth Amendment to the US Constitution and Article I, Section 10 of the Ohio Constitution. III. Law and analysis

A. Prison attire

Prior to jury voir dire, Letner posed an objection to the prison attire.

“[A] defendant cannot be compelled to go to trial in jail clothes, your Honor, it is

prejudicial, and there is no way to get around it.” (Tr. 27.) Letner accurately cites

the United States Supreme Court’s decision in Estelle v. Williams, 425 U.S. 501, 504,

96 S.Ct. 1691, 48 L.Ed.2d 126 (1976), for the premise that the due process rights of

a defendant may be violated where the defendant “stands trial before a jury while

dressed in identifiable jail clothes.” State v. R.W., 8th Dist. Cuyahoga No. 110858,

2022-Ohio-2771, ¶ 24, citing id.

The Estelle Court recognized that “the constant reminder of the

accused’s condition implicit in such distinctive, identifiable attire may affect a

juror’s judgment.” Id., citing id. at 504; see also Holbrook v. Flynn, 475 U.S. 560,

568, 106 S.Ct. 1340, 89 L.Ed.2d 525 (1986). Acknowledging that a defendant may

“choose to wear identifiable jail clothing ‘in the hope of eliciting sympathy from the

jury,’” the court “declined to establish a bright-line rule requiring a conviction to be

reversed where the defendant appeared before the jury in jail clothing.” Id., quoting

Estelle at 507-508.

First, a defendant must show that he was compelled to stand trial

before a jury dressed in identifiable jail attire to establish that a constitutional

violation occurred. R.W. at ¶ 25, citing State v. Trowbridge, 1st Dist. Hamilton No. C-110541, 2013-Ohio-1749, ¶ 28. Secondly, a defendant must show that he was

prejudiced by the compulsion. Id.

The trial court explained in this case:

Court: I’m not compelling him to go to trial and neither is the executive branch of government.

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 610, 209 N.E.3d 925, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-letner-ohioctapp-2023.