State v. Reillo

2024 Ohio 3307, 250 N.E.3d 1229
CourtOhio Court of Appeals
DecidedAugust 29, 2024
Docket113531
StatusPublished
Cited by1 cases

This text of 2024 Ohio 3307 (State v. Reillo) 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. Reillo, 2024 Ohio 3307, 250 N.E.3d 1229 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Reillo, 2024-Ohio-3307.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 113531 v. :

NELSON REILLO, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND REMANDED RELEASED AND JOURNALIZED: August 29, 2024

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-23-680671-A

Appearances:

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

Russell S. Bensing, for appellant.

SEAN C. GALLAGHER, J.:

Nelson Reillo appeals his convictions for rape and gross sexual

imposition, which resulted in an aggregate life term of imprisonment with the

possibility of parole after 15 years. For the following reasons, we reverse Reillo’s

convictions and remand for a new trial. At the outset we note that reversing convictions based on manifest

weight is a rare occurrence. Our determination, and thus our view that this case is

a rare and exceptional case requiring reversal, should be limited to the facts and

circumstances of this case. It should not be read as an expansion of any existing

legal standard.

The facts underlying the convictions are established through the

testimony of the 20-year-old alleged victim, E.C., recounting two encounters

approximated to have occurred 12 years prior. Sometime in the year 2020, E.C.,

who was 17 years old at the time, told a medical professional about Reillo’s alleged

abuse that occurred when E.C. was approximately eight years old. It does not appear

that any details of the abuse were then provided, but the medical provider was

obligated to report the disclosure to the authorities. Nevertheless, and for unknown

reasons, the State did not obtain an indictment until three years after the initial

disclosure and investigation.

E.C. is the youngest of three siblings, the eldest being seven years

older. E.C. began seeing mental health professionals during high school but did not

disclose the sexual abuse to them, claiming that as a sophomore in high school, “I

was not out with that information at that time, so I didn’t get to talk about it.”

Tr. 386:2-5. However, E.C. also claimed to have told an older sister and two friends

a year before starting that therapy. Neither the sister nor the friends testified, nor is

the extent of those disclosures known. E.C. claimed to have told the friends because

“I had never told anyone before and it was starting to weigh on my mental health and I thought that it would be nice to talk to someone about it.” Tr. 398:6-9.

According to E.C.’s trial testimony, E.C.’s sister “guessed” that the abuse had

occurred at the time of that disclosure. It was also claimed the disclosure was not

immediate when E.C. was “eight, when she’s in middle school, [and] when she’s in

high school” because “it does make sense that a kid in that situation would want to

protect their mom.” Tr. 496:12-15.

The State presented four witnesses at trial, three of whom provided

no relevant evidence establishing proof of the alleged criminal conduct. The medical

professional had no independent recollection of any statements beyond E.C.

reporting having been “sexually abused.” The social worker testified to interviewing

E.C. following the disclosure, but she does not appear to have been provided any

details of the alleged abuse, just a blanket statement that it occurred. Also, on this

issue the State made a point to inquire into whether E.C. disclosed any details of the

sexual assaults to the medical care provider or social worker following the initial

disclosure. At first, E.C. claimed to have done so, but in follow up, the State asked

for clarification:

Q. Okay. Just to clarify and take you back before the video interview with the medical exam when you tell your pediatrician. Did you tell your pediatrician the details that you are telling us here today or did you keep it general with your pediatrician?

A. I kept it general.

Tr. 396:18-24. The detective testified that the investigation consisted of interviewing

E.C.’s sister and mother, but he inexplicably did not interview E.C., E.C.’s brother,

or father, or otherwise conduct any other form of investigation to verify the

allegations contained in the reporting. Tr. 452:1-15. Importantly, despite his 20-

minute interview of E.C.’s sister, to whom the disclosures had allegedly been made

before 2020, the detective had no information about any prior disclosures made by

E.C. Tr. 455:17-23. E.C. seemingly confirmed that fact during cross-examination,

despite testifying to the contrary during the direct:

Q. Okay. And you visited with your dad, but you didn’t tell your dad, correct?

A. Correct.
Q. And you [n]ever told your brother, correct? And you never told your sister?
A. Yes.

(Emphasis added.) Tr. 420:19-24.

In light of the lack of details provided to the medical care provider and

social worker, when coupled with the detective’s lack of an interview with E.C., it

appears from this record that the extent of the alleged sexual abuse, beyond that

which was included in the indictment, was not disclosed before trial. This

observation is borne out by the State’s opening statement, which was limited to

generic statements that the State intended to call E.C. to testify to “how she knows

Mr. Reillo and what happened to her.” The prosecutor did not elaborate on that

statement. Turning to the facts underlying the offense, E.C.’s mother had a

relationship with Reillo, who moved into the family’s home for less than a year. E.C.

was unable to provide a definitive time frame, and no other evidence demonstrated

when Reillo lived in the same home as E.C. E.C. could not recall at what time of year

the encounters occurred. The State guessed the events occurred between July 2011

and July 2012 in light of E.C.’s date of birth and testimony that E.C. was “about

eight” years old at the time — using the year E.C. was eight years old as the date of

the conduct. E.C. testified that on two occasions, Reillo committed acts constituting

rape and gross sexual imposition, both incidents occurring in the bedroom Reillo

shared with E.C.’s mother.

Once while sitting on Reillo’s lap, E.C. described being moved to the

desk where he was sitting. Reillo removed E.C.’s pants and put his mouth on E.C.’s

vagina. There is no evidence that Reillo removed E.C.’s underwear. Tr. 393:11-14.

E.C. could not recall if anything was said, if anyone else was present in the home, or

how the encounter ended, much less provide any other detail surrounding the

encounter — with one exception. There was testimony of a memory that E.C. “could

feel like my [vaginal] lips like opening” at the time of the assault. Tr. 392:7-20. That

testimony, however, was elicited through a leading inquiry by the State after E.C.

first provided a vague, almost nonresponsive answer to a similar narrative question

probing for details of the assault. Tr. 392:4-12.

E.C. described that in a second encounter, Reillo was on the bed, lying

on his back. He had a large towel only covering his “private area,” but his state of undress was unknown. He placed E.C. “over” his “private area” but “on” the towel

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Related

State v. Butler
2024 Ohio 5879 (Ohio Court of Appeals, 2024)

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Bluebook (online)
2024 Ohio 3307, 250 N.E.3d 1229, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-reillo-ohioctapp-2024.