State v. Simko

1994 Ohio 350, 71 Ohio St. 3d 483
CourtOhio Supreme Court
DecidedDecember 30, 1994
Docket1993-0569
StatusPublished
Cited by76 cases

This text of 1994 Ohio 350 (State v. Simko) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Simko, 1994 Ohio 350, 71 Ohio St. 3d 483 (Ohio 1994).

Opinions

Francis E. Sweeney, Sr., J.

Beginning in State v. Poindexter (1988), 36 Ohio St.3d 1, 3, 520 N.E.2d 568, 570, and recently reiterated in State v. Scudder (1994), 71 Ohio St.3d 263, 643 N.E.2d 524, we expressed the view that when we review death penalty cases, our obligation under the law does not require us to address all propositions of law in opinion form. We adhere to this view today, and therefore summarily dispose of many propositions of law where either the error was not properly preserved or the propositions have been decided adversely to the appellant. In doing so, we hasten to add that although this opinion does not separately address each of the twenty-one propositions of law (see Appendix), we have fully reviewed the record and passed upon each one prior to reaching our decision. In addition, we independently assessed the evidence relating to the death sentence, balanced the aggravating circumstance against the mitigating factors, and reviewed the proportionality of the sentence to sentences imposed in similar cases. As a result, we affirm the convictions and sentence, including the death penalty.

[488]*488I

GUILT PHASE

Sufficiency of Evidence

In Proposition of Law I, appellant challenges the sufficiency of the evidence for the capital specification and for the separate kidnapping offense charged in count two.1

The capital specification appellant was convicted of was kidnapping: “committing, attempting to commit, or fleeing immediately after committing or attempting to commit kidnapping.” R.C. 2929.04(A)(7). Appellant was also convicted of the separate offense of kidnapping Johnson. R.C. 2905.01, as charged in this case, involves the removing of a person by force, threat, or deception from the place where she is found, or restraining her of her liberty, to terrorize or inflict serious harm on the victim. R.C. 2905.01(A)(3).

Appellant argues that under this court’s decision in State v. Logan (1979), 60 Ohio St.2d 126, 14 O.O.3d 373, 397 N.E.2d 1345, the state failed to present sufficient evidence of either the elements of kidnapping or a separate animus from the animus to commit aggravated murder to sustain his convictions on these charges. Appellant asserts that the alleged kidnapping of Johnson was incidental to the murder, as in State v. Jenkins (1984), 15 Ohio St.3d 164, 198, 15 OBR 311, 340, 473 N.E.2d 264, 295 (no kidnapping where restraint was in a public bank and incidental to robbery).

In Logan, supra, this court held that where the murder is the underlying crime, “a kidnapping in facilitation thereof would generally constitute a separately cognizable offense.” Id., 60 Ohio St.2d at 135, 14 O.O.3d at 379, 397 N.E.2d at 1352. However, the test to determine whether the kidnapping was committed with a separate animus and thus amounts to a separate offense is “whether the restraint or movement of the victim is merely incidental to a separate underlying crime, or instead, whether it has a significance independent of the other offense.” Id. at 135, 14 O.O.3d at 378, 397 N.E.2d at 1351.

In State v. Seiber (1990), 56 Ohio St.3d 4, 14, 564 N.E.2d 408, 420, we found kidnapping where bar patrons were repeatedly ordered to lie on the floor while defendant and his accomplice had drawn guns. When another bystander refused to comply with the demands, he was shot and killed. Under these circumstances, this court held that it was reasonable for a jury to conclude that Seiber had restrained that victim of his liberty and that this evidence was sufficient to support the kidnapping charge and specification.

[489]*489Clearly, the instant facts present a more compelling case of kidnapping than even Seiber. According to Harold Baker’s testimony, Johnson was restrained and terrorized by the armed appellant for approximately one-half hour. Further evidence indicated that Johnson managed to escape from appellant, but appellant shot her twice in the back while she was fleeing down the school hallway. Thus, contrary to appellant’s assertion, the evidence and testimony indicate that Johnson’s kidnapping was completed prior to the murder, and appellant did not murder Johnson until she fled from him. Therefore, the prosecution presented sufficient evidence to prove not only kidnapping, but also an animus for kidnapping separate from the aggravated murder. We reject this proposition of law.

In Proposition of Law VIII, appellant argues that the state failed to introduce evidence sufficient to convict him of kidnapping Harold Baker. Appellant contends that “any movement of Harold Baker was incidental to the murder of Mary Jane Johnson.”

This proposition of law is also without merit. A review of the evidence reveals that it was sufficient to support appellant’s conviction for kidnapping Baker.

. Baker testified that when he encountered appellant in the teachers’ lounge, appellant had a gun in one hand and an arm around Johnson. When Baker attempted to help Johnson, appellant told him to “get the hell out of here.” When Baker reached for the door leading out to the hallway, appellant told him “No, not there” and motioned with the gun for Baker to go into the teachers’ lounge restroom. After removing the screen from the window, Baker managed to escape. This testimony clearly indicated that Baker was restrained of his liberty to exit the teachers’ lounge and was forced by appellant to enter the lounge restroom which had no outside exit. Moreover, Baker testified he was “scared” because appellant had a gun, thus demonstrating appellant’s terrorizing of Baker (and inferentially Johnson). We reject this proposition of law.

Hearsay

In Proposition of Law VI, appellant argues that the trial court improperly admitted prejudicial hearsay testimony that did not qualify as an exception under either Evid.R. 804(B)(2) — dying declaration, or Evid.R. 803(2) — excited utterance.

The testimony was elicited from Detective Bruce Johnston of the Lorain County Sheriffs Department. Defense counsel challenged Detective Johnston’s testimony on the grounds that the dying declaration exception did not apply, since the victim had no reason to believe she was dying at the time Detective Johnston questioned her. In response, the prosecution claimed that it was relying not only on the dying declaration exception, but also on the excited utterance exception applied in State v. Huertas (1990), 51 Ohio St.3d 22, 31, 553 N.E.2d 1058, 1068. The trial court then permitted the detective’s testimony. [490]*490The prosecution now concedes that the declaration does not qualify as a dying declaration under Evid.R. 804(B)(2). However, the state asserts it is admissible under the excited utterance exception.

In Huertas, id. at 31, 553 N.E.2d at 1068, this court, quoting paragraph two of the syllabus in Potter v. Baker (1955), 162 Ohio St. 488, 55 O.O. 389, 124 N.E.2d 140, set forth the standard for the excited utterance exception: “To be admissible under Evid.R.

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Bluebook (online)
1994 Ohio 350, 71 Ohio St. 3d 483, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-simko-ohio-1994.