State v. McKinney

Procedural entryThis page is a short order in State v. McKinney. Read the opinion of the Court — 2024 Ohio 4642
Ohio Court of Appeals·Decided July 17, 2026·No. 2025-CA-56; 2025-CA-63·Published

Opinion

[Cite as State v. McKinney, 2026-Ohio-2742.]

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

STATE OF OHIO : : C.A. Nos. 2025-CA-56; 2025-CA-63 Appellee : : Trial Court Case Nos. 24-CR-0656; 25- v. : CR-0437; 24-CR-0356; 25-CR-0217 : DAVID MCKINNEY : (Criminal Appeal from Common Pleas : Court) Appellant : : FINAL JUDGMENT ENTRY & OPINION ...........

Pursuant to the opinion of this court rendered on July 17, 2026, the judgments of the

trial court in Clark C.P. Nos. 24-CR-0356 and 25-CR-0217 are vacated in part, the judgment

in Clark C.P. No. 25-CR-0437 is reversed in part, and the matter is remanded for

resentencing in Clark C.P. No. 25-CR-0437 consistent with the opinion.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

send a copy of the court’s ruling to each party and note that action on the docket.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MARY K. HUFFMAN, JUDGE

LEWIS, P.J., and HANSEMAN, J., concur. OPINION CLARK C.A. Nos. 2025-CA-56; 2025-CA-63

CHRISTOPHER J. PAGAN, Attorney for Appellant JOHN M. LINTZ, Attorney for Appellee

HUFFMAN, J.

{¶ 1} In these consolidated cases, David McKinney appeals from judgment entries of

conviction on three counts of menacing by stalking, two counts of violating a protection order,

and one count of unlawful restraint. Because duplicity in the indictment and in the charge

are demonstrated, McKinney’s protection order violation convictions are vacated. The matter

is remanded for a resentencing hearing limited to the proper imposition of post-release

control in the sentence on the felony menacing by stalking offense.

Facts and Procedural History

{¶ 2} Over a course of many months, McKinney was indicted as follows: in May 2024,

on two counts of menacing by stalking and one count of violating a protection order (Clark

C.P. No. 24-CR-0356); in August 2024, on one count of abduction (Clark C.P. No. 24-CR-

0656); in March 2025, on two counts of menacing by stalking and one count of violating a

protection order (Clark C.P. No. 25-CR-0217); and in June 2025, on one count of menacing

by stalking (Clark C.P. No. 25-CR-0437). The victim in each offense, S.P., was McKinney’s

former live-in girlfriend.

{¶ 3} The cases progressed to a consolidated five-day jury trial on June 16, 2025,

where 10 witnesses testified for the State, and McKinney called six witnesses and testified

himself. At the conclusion of the State’s case, McKinney moved for acquittal, and the trial

court granted the motion as to two counts of menacing by stalking, one in Clark C.P. No. 24-

CR-0356 and the other in Clark C.P. No. 25-CR-0217. The jury returned guilty verdicts on

2 three felonies: two counts of violating a protection order in Clark C.P. Nos. 24-CR-0356 and

25-CR-0217 and menacing by stalking in Clark C.P. No. 25-CR-0437. The jury also found

McKinney guilty of three misdemeanors as lesser-included offenses of the counts charged

in his indictments: two counts of menacing by stalking in Clark C.P. Nos. 24-CR-0356 and

25-CR-0217 and one count of unlawful restraint in Clark C.P. No. 24-CR-0656.

{¶ 4} Disposition occurred on July 29, 2025. The court imposed 18 months on the

protection order violation in Clark C.P. No. 24-CR-0356, 24 months on the protection order

violation in Clark C.P. No. 25-CR-0217, and 18 months for menacing by stalking in Clark

C.P. No. 25-CR-0437. The court ordered the felony sentences to be served consecutively

to each other for a total term of 60 months; local jail time was imposed for the misdemeanor

offenses, to be served concurrently with the felonies. Only the felony offenses are at issue

in this timely appeal.

Assignments of Error and Analysis

I.

{¶ 5} McKinney asserts two assignments of error. In his first assigned error, he

argues that his convictions for violating a protection order were contrary to law for two

reasons. First, he claims that the State improperly indicted the offenses as continuing course

of conduct crimes, eliciting evidence of multiple contacts between him and S.P. without

identifying the two specific contacts that constituted the crimes charged; according to

McKinney, this was “duplicitous twice over: as charged and as presented at trial.” Put

differently, McKinney argues that evidence of over 100 protection order violations was

introduced, and the state failed to identify the specific act it alleged was charged in the

indictment. McKinney asserts that such a duplicitous prosecution was contrary to law,

because it violated Crim.R. 8(A), his right to be charged by a grand jury, his right to know

3 the accusations against him, his right to juror unanimity, and his right to avoid double

jeopardy.

{¶ 6} Because defense counsel did not raise the issue of duplicity before the trial

court, McKinney argues that plain error analysis applies. He claims that the duplicity affected

the trial outcome, because he contested specific alleged violations, “but the indictment, . . .

trial presentation, and verdict failed to identify [two] specific acts that violated the statute.”

He asserts that the trial court “committed serious constitutional error by authorizing course-

of-conduct charge[s] and theory, that [the] error was plain and obvious, and it denigrated

[his] substantial rights by affecting the trial outcome.” McKinney does not appear to argue

that he could not have been convicted, as a result of his conduct, of the violation of a

protection order. Instead, he claims that the presentation of evidence and the indictment did

not identify the specific act in each count that the jury was to consider and that he was to

defend against.

{¶ 7} “Issues regarding duplicity first appeared in Ohio in the case of Barnhouse v.

State, 31 Ohio St.3d 39 (1876),” to which McKinney directs our attention. State v.

Blankenburg, 2012-Ohio-1289, ¶ 133 (12th Dist.) (Ringland, J., concurring in part and

dissenting in part). Barnhouse was indicted and tried on one count of incest, but the evidence

at trial established that his incestuous behavior occurred continually between 1865 and

1876. Id. After noting that incest is a single-act crime, the Ohio Supreme Court reversed

Barnhouse’s conviction, finding that an “‘indictment for incest which charges the criminal act

[had] been committed continuously through a specified period of years, is to be regarded as

charging several distinct offenses, and is bad for duplicity.’” (Bracketed text in original.) Id.,

quoting Barnhouse at 39.

4 {¶ 8} “The prohibition against duplicity serves two key purposes: it protects an

accused’s Sixth Amendment right to receive notice of the nature of the charge and prevents

confusion regarding the basis for the verdict.” State v. Jones, 2026-Ohio-68, ¶ 29

(12th Dist.). “Although most courts addressing this issue treat the concept as a single

doctrine, duplicity manifests in two distinct forms: (1) duplicity in the indictment, and

(2) duplicity in the charge.” Id., citing Blankenburg at ¶ 130.

{¶ 9} Duplicity in the indictment is more common and “occurs when two or more

distinct offenses are alleged in a single count.” Id.

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