State v. Santos

2020 Ohio 1043
CourtOhio Court of Appeals
DecidedMarch 20, 2020
Docket28445
StatusPublished
Cited by3 cases

This text of 2020 Ohio 1043 (State v. Santos) 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. Santos, 2020 Ohio 1043 (Ohio Ct. App. 2020).

Opinion

[Cite as State v. Santos, 2020-Ohio-1043.]

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

STATE OF OHIO : : Plaintiff-Appellee : Appellate Case No. 28445 : v. : Trial Court Case No. 2018-CR-1840 : ERIC ALEXANDER SANTOS : (Criminal Appeal from : Common Pleas Court) Defendant-Appellant : :

...........

OPINION

Rendered on the 20th day of March, 2020.

MATHIAS H. HECK, JR., by HEATHER N. KETTER, Atty. Reg. No. 0084470, Assistant Prosecuting Attorney, Montgomery County Prosecutor’s Office, Appellate Division, Montgomery County Courts Building, 301 West Third Street, Dayton, Ohio 45422 Attorney for Plaintiff-Appellee

ROBERT ALAN BRENNER, Atty. Reg. No. 0067714, P.O. Box 340214, Beavercreek, Ohio 45434 Attorney for Defendant-Appellant

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

WELBAUM, J. -2-

{¶ 1} Defendant-Appellant, Eric Alexander Santos, appeals from his conviction in

the Montgomery County Court of Common Pleas after pleading no contest to tampering

with evidence with a one-year firearm specification. In support of his appeal, Santos

challenges the trial court’s denial of his motion to suppress statements obtained by law

enforcement officers in the course of a homicide investigation. He further challenges the

trial court’s denial of his motion to dismiss the firearm specification accompanying the

tampering charge. Because the motions were not denied in error, the judgment of the trial

court will be affirmed.

I. Facts and Course of Proceedings

{¶ 2} On the night of February 1, 2016, police were called to a residence on

Curundu Avenue in Trotwood, Ohio. Two men seated in a vehicle in the driveway had

been fatally shot. Lead investigator Patrick Craun, a 12-year veteran of the Trotwood

Police Department, responded to the scene sometime after 10:00 p.m. Thereafter, a

fellow officer informed Detective Craun that a civilian at the perimeter of the crime scene

said he lived in the house. That man was 19-year-old Eric Santos.

{¶ 3} Detective Craun approached Santos and his girlfriend, Aiste Maksvytyte. He

asked if Santos would come to the police station to answer a few questions to help the

officers piece together what had happened. Santos agreed. He rode to the station in the

front seat of Detective Craun’s unmarked sedan, unrestrained. The detective did not

question Santos while en route.

The Trotwood Police Department Interview

{¶ 4} A short ride later, the two men arrived at the Trotwood Police Department

and entered the building through a rear door. Detective Craun directed Santos to a -3-

conference room. Santos remained unrestrained. The detective explained that he wished

to ask some questions pertaining to a homicide investigation. Santos asked if his

roommate was one of the victims, but the detective did not answer because the victims’

next of kin had not yet been notified.

{¶ 5} According to Detective Craun, Santos seemed to understand why he was

there. The detective asked basic questions concerning the inhabitants of the residence,

when Santos was home last, the last time he spoke with anyone at the residence, how

he heard about what had happened, and why he came to the scene. The interview lasted

approximately 30 to 45 minutes.

{¶ 6} At the close of the interview, Detective Craun asked Santos to write out a

witness statement. Santos complied. The detective left the room at one point, and he

collected the completed statement when he returned. Santos remained in the conference

room while the detective went to speak with other witnesses, including Aiste Maksvytyte.

{¶ 7} Unbeknownst to Detective Craun, there was an active warrant for Santos’s

arrest out of Greene County. A police department employee discovered the warrant while

Detective Craun was interviewing Santos. Santos was taken into custody and, thereafter,

transported to Greene County.

The Greene County Jail Interview

{¶ 8} The next day, Detective Craun received word that Santos’s girlfriend, Aiste,

had returned to the Trotwood police station. She confessed that she had lied about events

from the previous night. Aiste indicated that Santos was, in fact, present at the house

when the homicides occurred. Based upon this information, Detective Craun and Captain

Dan Heath traveled to the Greene County Jail to speak with Santos that evening. The -4-

interview took place in a small room off of the common area in the jail. The room was not

equipped for recording, but Detective Craun brought along a digital voice recorder to

capture audio.

{¶ 9} Detective Craun reviewed Santos’s constitutional rights prior to commencing

questioning. He provided Santos with a standard form enumerating the rights in writing.

The detective explained that he would read each of the rights out loud while Santos

followed along on his own copy. Santos was to answer yes or no after each right was

read to him lyand initial in the corresponding space next to each right. The detective

further indicated there was a waiver of rights statement at the end of the form that Santos

would be asked to read, and then he would sign and date the form.

{¶ 10} Detective Craun reviewed the rights section of the form with Santos at least

twice. The process was not seamless. Nonetheless, at its conclusion, the detective was

satisfied that Santos understood his rights. Santos did not ask any questions about

waiving his rights. Instead, when asked if he wished to speak with the officers without

counsel, he replied, “Yeah. Yeah. Yeah.” Despite this apparent eagerness, however, the

detective did not believe Santos was being forthcoming in answering questions. After

nearly 40 minutes, Santos indicated he was done talking. The officers continued to probe,

eliciting further incriminating statements. Santos again indicated his wish to stop talking.

The officers pressed further before finally concluding the interview.

Criminal Prosecution in Montgomery County

{¶ 11} In August 2018, Santos was charged with one count of tampering with

evidence in violation of R.C. 2921.12(A)(1), a third-degree felony. The charge was

accompanied by a one-year firearm specification under R.C. 2929.14 and 2941.141. By -5-

way of a motion filed in November 2018, Santos sought to suppress the incriminating

statements he made during the interview at the Trotwood Police station and during the

interview at the Greene County Jail. Following a hearing, the trial court suppressed the

statements made after Santos indicated his desire to halt the interview at the Greene

County Jail, but denied the motion in all other respects.

{¶ 12} In February 2019, Santos moved to dismiss the firearm specification in the

indictment. The trial court denied the motion. Thereafter, Santos entered a no contest

plea to the tampering charge and firearm specification. He was sentenced to 36 months

in prison, which was ordered to run concurrently to a term he was serving on an unrelated

case out of Miami County. The one-year term on the firearm specification was ordered to

run consecutively to this term.

{¶ 13} Santos now appeals, raising two assignments of error for our review.

II. Suppression of Statements

{¶ 14} In his first assignment of error, Santos argues that the trial court wrongly

declined to suppress the incriminating statements he made to police while being

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2020 Ohio 1043, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-santos-ohioctapp-2020.