State v. Sanders

2024 Ohio 1026
CourtOhio Court of Appeals
DecidedMarch 20, 2024
DocketC-230393
StatusPublished

This text of 2024 Ohio 1026 (State v. Sanders) 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. Sanders, 2024 Ohio 1026 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Sanders, 2024-Ohio-1026.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-230393 TRIAL NOS. B-1300037 Plaintiff-Appellee, : B-1305979

vs. : O P I N I O N. DEANGELO SANDERS, :

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgments Appealed From Are: Affirmed

Date of Judgment Entry on Appeal: March 20, 2024

Melissa A. Powers, Hamilton County Prosecuting Attorney, and John D. Hill, Jr., Assistant Prosecuting Attorney, for Plaintiff-Appellee,

Deangelo Sanders, pro se. OHIO FIRST DISTRICT COURT OF APPEALS

CROUSE, Judge.

{¶1} Defendant-appellant Deangelo Sanders appeals the judgments of the

Hamilton County Court of Common Pleas denying his motion for a new trial and

dismissing his “Successive Motion to Vacate or Set Aside the Judgment of Conviction

and/or Sentence.” For the following reasons, we affirm the lower court’s judgments.

Factual and Procedural History

{¶2} In 2014, Sanders was convicted upon jury verdicts of two counts of

aggravated murder in violation of R.C. 2903.01(B), with accompanying firearm

specifications, two counts of aggravated robbery, and having a weapon while under a

disability. The trial court imposed an aggregate sentence of 77 years to life in prison.

At trial, Sanders, through counsel, acknowledged that he and his codefendant had

planned to sell drugs to the two victims, but maintained that he had come to the drug

deal unarmed and that his codefendant had unexpectedly and without Sanders’s

knowledge decided to kill the victims when the victims resisted the robbery. On direct

appeal, we affirmed Sanders’s convictions and sentence. State v. Sanders, 1st Dist.

Hamilton Nos. C-140579 and C-140580, 2015-Ohio-5232, delayed appeal not

allowed, 146 Ohio St.3d 1413, 2016-Ohio-3390, 51 N.E.3d 658.

{¶3} On February 21, 2023, Sanders filed both a delayed motion for a new

trial (after the common pleas court had granted him leave to do so) and a “successive

motion to vacate judgment of conviction and/or sentence.” In his motion for a new

trial, Sanders argued that he is entitled to a new trial based on an error of law, see

Crim.R. 33(A)(1), and an irregularity in the trial proceedings, see Crim.R. 33(A)(4).

Under these two grounds, Sanders asserts that his “Sixth Amendment right to a jury

trial was violated when he was sentenced by a single judge on a capital offense.”

(Notably, the record demonstrates that the aggravated-murder charges did not include

a death-penalty specification.) Next, Sanders contends he is entitled to a new trial

based on newly discovered evidence. See Crim.R. 33(A). Under this ground, Sanders

2 OHIO FIRST DISTRICT COURT OF APPEALS

claims that he recently obtained the affidavit of Gracie Gallagher, which he asserts

“presents information that [Sanders] may not have been involved in the murders.”

Gallagher’s affidavit is not in the record, nor was it attached to the delayed motion for

a new trial.

{¶4} In his motion to vacate, Sanders cites R.C. 2953.21, Ohio’s

postconviction statute, and presents three grounds for relief. He claims that his trial

counsel was ineffective for (1) failing to object to a judge, instead of a jury, imposing

his sentence when he had been charged with a capital offense; (2) failing to object to

the admission of a police officer’s hearsay testimony; and (3) failing to investigate and

interview Gracie Gallagher, a potential alibi witness who had information on whether

Sanders participated in the charged offenses. With respect to the third ground,

Sanders claims that Gallagher’s affidavit, which she executed in September 2022,

demonstrates that he could not have participated in the robbery and murder of the two

victims. Sanders did not attach the affidavit to his motion to vacate but summarized

the testimony in the affidavit as follows: Gallagher had been talking on the phone with

Sanders at the time of the robbery and murders, and shortly after their conversation

ended, Gallagher starting hearing talk of the murders from others. One week later,

Sanders’s codefendant approached Gallagher and Sanders in the hallway of

Gallagher’s apartment building and confessed that he had killed the two victims and

that he had been alone when doing so. Gallagher approached Sanders’s trial counsel

with information about the crimes, but she was not called as witness during Sanders’s

trial.

{¶5} In June 2023, the common pleas court summarily denied Sanders’s

motion for a new trial and dismissed Sanders’s motion to vacate. Sanders now

appeals, bringing forth five assignments of error.

3 OHIO FIRST DISTRICT COURT OF APPEALS

New-Trial Motion Lacks Merit

{¶6} Sanders argues under his first assignment of error that he was denied

due process when the common pleas court denied his new-trial motion without issuing

findings of fact and conclusions of law. We overrule this assignment of error. A trial

court has “no duty to issue findings of fact and conclusions of law when [it] denies a

Crim.R. 33 motion for a new trial.” State ex rel. Collins v. Pokorny, 86 Ohio St.3d 70,

711 N.E.2d 683 (1999), citing State v. Girts, 121 Ohio App.3d 539, 565, 700 N.E.2d 395

(8th Dist.1997).

{¶7} In his second assignment of error, Sanders contends that the common

pleas court abused its discretion by denying his motion for a new trial without first

conducting a “full hearing.” Under this assignment, Sanders only argues that the court

abused its discretion in denying his motion for a new trial based on the newly

discovered evidence of Gallagher’s affidavit.

{¶8} A motion for a new trial is warranted where the new evidence (1)

discloses a strong probability that it will change the result if a new trial is granted, (2)

has been discovered since the trial, (3) is such as could not in the exercise of due

diligence have been discovered before the trial, (4) is material to the issues, (5) is not

merely cumulative to former evidence, and (6) does not merely impeach or contradict

the former evidence. State v. Petro, 148 Ohio St. 505, 76 N.E.2d 370 (1947), syllabus.

{¶9} We review the denial of motion for a new trial for an abuse of discretion.

State v. Finnell, 1st Dist. Hamilton Nos. C-220440 and C-220441, 2023-Ohio-2563, ¶

14, citing State v. Schiebel, 55 Ohio St.3d 71, 564 N.E.2d 54 (1990), paragraph one of

the syllabus. Although Crim.R. 33(A) contemplates a hearing, it does not mandate an

evidentiary hearing on a motion for a new trial. State v. Hill, 1st Dist. Hamilton No.

C-180114, 2019-Ohio-365, ¶ 69. A trial court is not required to hold an evidentiary

hearing where the trial record demonstrates that the new-trial motion lacks merit. Id.

at ¶ 70.

4 OHIO FIRST DISTRICT COURT OF APPEALS

{¶10} Here, the record before the common pleas court demonstrated that

Sanders’s new-trial motion lacked merit. Sanders argues Gallagher’s affidavit

testimony demonstrates that he did not participate in the charged offenses because

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Related

State v. Sanders
2015 Ohio 5232 (Ohio Court of Appeals, 2015)
State v. Girts
700 N.E.2d 395 (Ohio Court of Appeals, 1997)
State v. Petro
76 N.E.2d 370 (Ohio Supreme Court, 1947)
State v. Apanovitch (Slip Opinion)
2018 Ohio 4744 (Ohio Supreme Court, 2018)
State v. Hill
2019 Ohio 365 (Ohio Court of Appeals, 2019)
State v. Schiebel
564 N.E.2d 54 (Ohio Supreme Court, 1990)
State ex rel. Collins v. Pokorny
711 N.E.2d 683 (Ohio Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1026, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sanders-ohioctapp-2024.