State v. Mowery

2024 Ohio 4507
CourtOhio Court of Appeals
DecidedSeptember 13, 2024
Docket2023-CA-40
StatusPublished
Cited by2 cases

This text of 2024 Ohio 4507 (State v. Mowery) 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. Mowery, 2024 Ohio 4507 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Mowery, 2024-Ohio-4507.]

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

STATE OF OHIO : : Appellee : C.A. No. 2023-CA-40 : v. : Trial Court Case No. 22-CR-889 : ALEX OWEN MOWERY : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on September 13, 2024

APRIL F. CAMPBELL, Attorney for Appellant

ROBERT C. LOGSDON, Attorney for Appellee

.............

TUCKER, J.

{¶ 1} Defendant-appellant Alex Owen Mowery appeals from his conviction for

attempted murder after he entered a guilty plea. Mowery argues that the State withheld

evidence prior to a probable cause hearing conducted by the juvenile court, thereby

necessitating reversal of the juvenile court’s decision to bind him over for trial as an adult. -2-

For the reasons set forth below, we reject this argument and affirm Mowery’s conviction.

I. Factual and Procedural History

{¶ 2} This case arises from a shooting that occurred on August 31, 2022. On that

date, Springfield police were dispatched to the area of Linden Avenue and East Pleasant

Street to meet with the victim; the victim stated that he had been in his vehicle when shots

were fired toward him by individuals in another vehicle. The victim informed police that

he had observed the driver point a handgun out of his window and fire three shots at him

before fleeing the scene.

{¶ 3} Following an investigation, Mowery was identified as the shooter. He was

17 years old when the offenses were committed. Mowery was charged in juvenile court

for offenses that, had he been an adult, would have constituted the crimes of attempted

murder, felonious assault, improper handling of a firearm in a motor vehicle, and

discharging a firearm at or near prohibited premises.

{¶ 4} The State asked the juvenile court to relinquish jurisdiction and bind Mowery

over to the general division of the common pleas court to be tried as an adult. As such,

a probable cause hearing was conducted on November 17, 2022. Of relevance hereto,

when the victim appeared in court to testify, he was wearing jail clothing. The prosecutor

noted the victim’s attire on the record and asked the victim whether he had been

incarcerated at the time of the shooting; the victim replied in the negative. On cross-

examination, defense counsel asked the victim why he was “in stripes,” and the victim

responded that he was in jail at that time for a felony charge of failure to comply with an -3-

order or signal of a police officer.

{¶ 5} The victim testified that, on the day of the shooting, he had been out driving

when he noticed a red car following him. According to the victim, he was approaching

his sister’s residence when he saw Mowery hold a gun out the driver’s window of the red

car and fire three shots at his vehicle. The victim stopped in his sister’s yard, and the

red car fled the scene. The victim’s sister had observed the shooting and called the

police. The victim observed bullet holes in his taillight, tire, and rear passenger door.

He testified that he knew Mowery as the younger brother of a man with whom the victim

had had previous disputes. The victim testified that he had seen Mowery three or four

times in the past and that he knew him as Alex.

{¶ 6} The victim’s sister testified she was outside her residence when she

observed the victim driving toward her. She also observed a red car chasing her brother

and she heard shots; the red car then sped away.

{¶ 7} Springfield Police Department Detective Ronald Jordan was assigned to

investigate the shooting. Jordan testified that after the victim informed him of the names

of the shooter and the shooter’s older brother, Jordan prepared a photographic array for

identification purposes. Another officer administered the identification process with the

victim, who identified Mowery as the shooter.

{¶ 8} Finally, Springfield Officer Christopher Slusher testified that he took pictures

of the victim’s vehicle after the shooting. The photographs corroborated the victim’s

testimony regarding the damage to his car caused by the shooting. Slusher testified that

one bullet had penetrated the rear door into the cabin of the vehicle, and he was able to -4-

recover that bullet.

{¶ 9} Following the hearing, the juvenile court found probable cause to believe

Mowery had committed the charged offenses. The court noted that Mowery had been

17 years and seven months old at the time of the offenses, and it concluded that the

transfer to the general division to be tried as an adult was mandatory.

{¶ 10} On December 6, 2022, Mowery was indicted on the charged offenses;

except for improper handling of a firearm, all the offenses included firearm specifications.

Thereafter, Mowery and the State entered into a plea agreement. Mowery pled guilty to

the charge of attempted murder; in exchange, the State dismissed all the other charges

and all the firearm specifications. The trial court sentenced Mowery to an indefinite term

of 8 to 12 years in prison.

{¶ 11} Mowery appeals.

II. Brady Material

{¶ 12} Mowery’s sole assignment of error is as follows:

BECAUSE MOWERY WAS NOT GIVEN BRADY INFORMATION

PRIOR TO HIS BINDOVER PROCEEDING, HIS CONVICTION SHOULD

BE REVERSED.

{¶ 13} Citing Brady v. Maryland, 373 U.S. 83 (1963), Mowery contends that the

State violated his constitutional rights when it failed to inform him prior to the probable

cause bindover hearing that the victim was in jail on a felony charge. He further claims -5-

that the victim had another felony conviction that was not disclosed by the State.1 Mowery

claims such information was exculpatory and provided a basis for impeaching the victim’s

testimony at the probable cause hearing.

{¶ 14} While not explicitly stated, Mowery appears to attack the jurisdiction of the

general division of the common pleas court by arguing that, if the State had provided the

information about the victim, there would have been no basis for the juvenile court to find

probable cause that Mowery had committed the criminal acts in question and, thus, there

would have been no transfer to the general division.

{¶ 15} In Brady, the United States Supreme Court held that a state violates the

due Process Clause of the Fourteenth Amendment to the United States Constitution by

suppressing evidence favorable to the accused where the evidence is material to guilt or

punishment. Id. at 87. The Ohio Supreme court has held that a juvenile facing a

probable cause hearing is, upon request, entitled to Brady materials from the state.

State v. Iacona, 93 Ohio St.3d 83, 91 (2001).

{¶ 16} To establish a Brady violation, a defendant must demonstrate 1) that the

evidence was favorable to the defendant, because it was either exculpatory or

impeaching, 2) that the evidence was willfully or inadvertently suppressed by the state,

and 3) that the defendant was prejudiced as a result. Strickler v. Greene, 527 U.S. 263,

281-282 (1999). Evidence is material or prejudicial “only if there is a reasonable

probability that, had the evidence been disclosed to the defense, the result of the

proceeding would have been different.

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2024 Ohio 4507, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mowery-ohioctapp-2024.