State v. Sutherland

2025 Ohio 488
CourtOhio Court of Appeals
DecidedFebruary 14, 2025
Docket2024-CA-6
StatusPublished
Cited by2 cases

This text of 2025 Ohio 488 (State v. Sutherland) 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. Sutherland, 2025 Ohio 488 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Sutherland, 2025-Ohio-488.]

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

STATE OF OHIO : : Appellee : C.A. No. 2024-CA-6 : v. : Trial Court Case No. 20CR00091 : JEFFREY SCOTT SUTHERLAND : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on February 14, 2025

MICHAEL T. COLUMBUS, Attorney for Appellant

JAMES DEAN BENNETT, Attorney for Appellee

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

HUFFMAN, J.

{¶ 1} Jeffrey Scott Sutherland appeals from the trial court’s denial of his petitions

for postconviction relief, which had alleged ineffective assistance of counsel and

prosecutorial misconduct. For the reasons that follow, the judgment of the trial court is

affirmed. -2-

Facts and Procedural History

{¶ 2} In December 2021, Sutherland was found guilty by a jury of two counts of

rape (child under 10) and sentenced to 25 years to life in prison. On direct appeal, we

found that his conviction for one count of rape (Count 1) had not been supported by

sufficient evidence, but that the evidence as to that count had supported a conviction on

the lesser-included offense of gross sexual imposition (GSI). We vacated the rape

conviction as to Count 1 and remanded for the trial court to modify its judgment to convict

Sutherland of GSI and sentence him for that offense. We affirmed Sutherland’s

conviction for rape as to Count 2. State v. Sutherland, 2022-Ohio-3079, ¶ 50 (2d Dist.).

{¶ 3} On February 17, 2023, Sutherland filed a petition for postconviction relief. He

raised issues of alleged ineffective assistance of counsel and prosecutorial misconduct.

Sutherland filed a second petition for postconviction relief on September 20, 2023, raising

the same issues. Sutherland supported his petitions with exhibits and his affidavits.

The State responded to both petitions.

{¶ 4} On February 7, 2024, the trial court denied Sutherland’s petitions without a

hearing. The court found that Sutherland’s allegations regarding ineffective assistance

of counsel were barred by the doctrine of res judicata, because they related directly to

matters in the trial record. Further, because new counsel had been appointed for

Sutherland on direct appeal, Sutherland could have made the ineffective assistance of

counsel allegations at that time, but he failed to do so. Accordingly, the court found that

Sutherland was barred from asserting a claim for ineffective assistance “based on matters

found in the trial record.” -3-

{¶ 5} The court found that Sutherland’s claim of ineffective assistance also relied

upon various items of evidence not utilized at trial: a report by children services; progress

notes by a counselor who treated the victim; Sutherland’s Police Academy Certificate; a

psychosexual report about Sutherland generated by a defense expert; and police

interview reports with witnesses. It was significant to the court that Sutherland did not

claim that the items were newly discovered evidence of material fact; rather, he argued

that the items should have been utilized by defense counsel but were not, and as such,

trial counsel was ineffective.

{¶ 6} The trial court observed that Sutherland had alleged numerous incidents of

ineffective communication between him and defense counsel during the case and at trial.

It was significant to the court that trial counsel had been retained by Sutherland, and he

could have retained substitute counsel if he believed trial counsel to be ineffective as

alleged. According to the court, this reason alone was sufficient for the court to conclude

that Sutherland’s allegations did “not state a substantial ground” for relief. The court

further noted that Sutherland had expressed satisfaction with trial counsel at the

conclusion of trial in response to questioning by the court.

{¶ 7} The court concluded that trial counsel had not been deficient, and even if

counsel should have offered additional material into evidence or communicated more

effectively with Sutherland, there was no “reasonable probability” that it would have

affected the outcome of the proceedings. Further, the court found that “the additional

proffered evidence would have been more harmful than helpful.” Accordingly, the court

determined that trial counsel’s errors, if any, were not so serious as to deprive Sutherland -4-

of a fair trial.

{¶ 8} Regarding prosecutorial misconduct, the court found that allegations of

ineffective communications or differences of opinion between Sutherland and trial counsel

did not provide substantive grounds for relief. The court noted that several of

Sutherland’s allegations were based on matters in the record, namely the prosecutor’s

comments during closing arguments, State’s Exhibit 5, and the State’s use of

Sutherland’s Google searches. The court found that res judicata barred Sutherland’s

claims and also noted that we previously had concluded that “It was error for the jury to

see the entirety of Exhibit 5, but it was harmless error as Sutherland’s substantial rights

were not abrogated.” Sutherland, 2022-Ohio-3079, at ¶ 25.

{¶ 9} Regarding Sutherland’s allegation of prosecutorial misconduct in the nature

of witness tampering, namely the prosecutor’s alleged nodding, head shaking, and facial

expressions during witness testimony, the court found that Sutherland’s reliance upon

State v. Tilley, 2012-Ohio-1533, ¶ 26 (8th Dist.), was misplaced. The trial court

distinguished Tilley, noting that the Eighth District “granted post-conviction relief because

the prosecutor’s questions ‘were improper and wrongfully impugned the credibility of the

defense witness,’ not because the prosecutor nodded in agreement with the witness.”

(Emphasis added.) The court found that it appeared “beyond a reasonable doubt that

the jury would have found the [Sutherland] guilty even absent the alleged misconduct.”

{¶ 10} After reviewing the record from the trial proceedings and the evidence filed

by the parties in the postconviction proceedings, the trial court concluded that Sutherland

had failed to establish substantive grounds for relief requiring a hearing. Noting that -5-

Sutherland’s attorney had provided significant detail in support of the allegations in the

petitions, including two affidavits by Sutherland and copies of the exhibits Sutherland

claimed should have been introduced at trial, the court further found that a hearing on the

pending motions “would not assist the Court – merely stating ‘in person’ what has already

been stated ‘in brief’ is not necessary. Plus, the exhibits attached to Defendant’s motion

require no oral explanation or context.”

{¶ 11} Sutherland appeals from the denial of his petitions without a hearing.

Assignments of Error and Analysis

{¶ 12} Sutherland’s first assignment of error is:

APPELLANT’S PETITIONS FOR POST-CONVICTION RELIEF

PRESENTED SUBSTANTIVE GROUNDS SUFFICIENT TO GRANT

RELIEF FROM CONVICTION LET ALONE A HEARING TO PERMIT THE

PRESENTATION OF EVIDENCE OUTSIDE THE TRIAL COURT AND

APPELLATE RECORDS.

Sutherland makes four arguments under this assignment of error: the

prosecutor engaged in misconduct by “intentionally delivering to the jury the highly

prejudicial and non-probative unredacted Exhibit 5”; the prosecutor tampered with

witness testimony, as allegedly reflected in video of the trial; the prosecutor

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Bluebook (online)
2025 Ohio 488, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sutherland-ohioctapp-2025.