State v. McCollum

2023 Ohio 69
CourtOhio Court of Appeals
DecidedJanuary 12, 2023
Docket111370
StatusPublished
Cited by1 cases

This text of 2023 Ohio 69 (State v. McCollum) 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. McCollum, 2023 Ohio 69 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. McCollum, 2023-Ohio-69.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 111370 v. :

CARLOS J. MCCOLLUM, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: January 12, 2023

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-21-661744-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Kevin R. Filiatraut, Assistant Prosecuting Attorney, for appellee.

Edward M. Heindel, for appellant.

LISA B. FORBES, J.:

Carlos J. McCollum (“McCollum”) appeals his convictions for

aggravated murder and other associated offenses. After reviewing the facts of the

case and pertinent law, we affirm the trial court’s decision. I. Facts and Procedural History

This case involves the July 17, 2021 murder of Kenneth Marks

(“Marks”). The facts of this case are undisputed. McCollum killed Marks by

shooting him in the left shoulder and chest area and beating his face and head with

a claw hammer.

On July 26, 2021, McCollum was charged with a ten-count indictment

including one count of aggravated murder, two counts of murder, two counts of

felonious assault, one count of having weapons while under disability, two counts of

aggravated robbery, and two counts of robbery, along with firearm, repeat violent

offender, and notice of prior conviction specifications. The case proceeded to trial,

and on March 11, 2022, McCollum was found guilty as indicted. On March 15, 2022,

the court sentenced McCollum to life in prison with the possibility of parole after 47-

49.5 years.

II. Assignments of Error

On appeal, McCollum raises six assignments of error for our review.

1. The trial court erred when it denied McCollum’s motion for a mistrial after McCollum’s outburst.

2. The trial court erred when it failed to instruct the jury to disregard McCollum’s outburst.

3. The trial court erred when it required the parties to exercise their peremptory challenges without the prospective jurors being present in the jury box.

4. The convictions were not supported by sufficient evidence.

5. The convictions were against the manifest weight of the evidence. 6. The Reagan Tokes act is unconstitutional because it violates the Due Process Clauses of the United States and Ohio constitutions, the separation of powers doctrine embodied in the Ohio Constitution, and the right to a jury trial as guaranteed by the United States and Ohio Constitution.

III. Law and Analysis

A. McCollum’s Outburst

During the prosecutor’s opening statement at trial, he said the

following to the jury: “[Y]ou’ll hear Ernest Hill and Jesse [sic] Jones testify [that

McCollum] told [them], give me your phones, don’t call 911, don’t do that, and said

to them, pointing at * * * Marks, I heard he, referring to * * * Marks, was telling

people he raped me.”

McCollum interrupted the prosecutor and stated the following in

open court:

M****r f*****g truth. As God [i]s my witness. Kill me now. That man sodomized me. You think I woke up and killed him for nothing? You think I killed him for nothing? Not my life, my career, my kids, my house, my home, my job. You think I did that for nothing? That’s my little cousin. I know that boy for 36 years.

***

I just woke up and killed him for nothing? Huh? For nothing? I did that, right? Huh?

And you know me, Mr. Morris. You know me. You know me. You know them. You arrested them many of times.

After this outburst, the judge had McCollum temporarily removed

from the courtroom to calm down. When the proceedings reconvened, defense

counsel moved for a mistrial, stating the following on the record in the jury’s presence: “Unfortunately during the outburst in the presence of the jury my client

made some admissions, a lot of admissions, that cannot by unheard by the jury. And

his demeanor exhibited a lot of anger and things that all will prejudice him in any

proceedings going forward with this jury. Therefore, we ask the court to declare a

mistrial.”

The court denied McCollum’s request and noted that “these were

opening statements. And the court will instruct the jury and we’ll proceed.” The

court then instructed the jury as follows:

Ladies and gentlemen of the jury, we are going to continue with opening statements * * *. Please remember, as I stated to you before, that you are to listen to the evidence from the witness stand, not from the parties, not from opening statements made by counsel. Your attention is to be drawn to the evidence that will be presented in this court through witnesses, direct evidence and stipulations as has been explained to you already. So please be mindful of that in your deliberations. And the information that you are to take in to consider comes from those sources.

The next morning, prior to the continuation of witness testimony, the

following colloquy took place between a juror and the court:

JUROR: Judge * * *, I do have a question. I have a question about testimony. I need some clarification. I think I know the answer, but I’m not sure.

So what I was wondering is, if the defendant’s remarks made yesterday were considered to be testimony?

THE COURT: I appreciate your question. As I instructed everyone yesterday, the testimony is to come from the witness stand, okay, and the exhibits and any stipulations that are received. That is the evidence that you would use for your deliberations. Based on this juror’s question, McCollum renewed his motion for a

mistrial. The court again denied his motion, finding that it “has no concerns that

this jury isn’t doing exactly what they’re supposed to be doing and that is to be

listening to the evidence that comes from the witness stand.”

1. Motion for a Mistrial

In his first assignment of error, McCollum argues that the trial court

should have granted his motion for a mistrial after his outburst before the jury. “The

grant[ing] or denial of an order of mistrial lies within the sound discretion of the

trial court. * * * Moreover, mistrials need be declared only when the ends of justice

so require and a fair trial is no longer possible.” State v. Garner, 74 Ohio St.3d 49,

59, 656 N.E.2d 623 (1995).

A “trial court must determine, as a question of fact, whether an

emotional outburst in a murder trial deprived the defendant of a fair trial by

improperly influencing the jury.” State v. Scott, 101 Ohio St.3d 31, 2004-Ohio-10,

800 N.E.2d 1133, ¶ 44. However, this court has held that when the defendant is the

culprit of the emotional outburst, the issue “falls under the invited error doctrine.”

State v. Williams, 8th Dist. Cuyahoga No. 106266, 2018-Ohio-3368, ¶ 40. In Hal

Artz Lincoln-Mercury v. Ford Motor Co., 28 Ohio St.3d 20, 502 N.E.2d 590 (1986),

paragraph one of the syllabus, the Ohio Supreme Court held that a “party will not be

permitted to take advantage of an error which he himself invited or induced.” In Williams, this court found that the trial court acted within its

discretion when it denied the defendant’s motion for a mistrial after he said the

following to a witness who was about to testify against him:

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2023 Ohio 69, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mccollum-ohioctapp-2023.