State v. Sutherland

2025 Ohio 488
Ohio Court of Appeals·Decided February 14, 2025·No. 2024-CA-6·Published·Cited by 2 cases

Opinion

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.

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.”

{¶ 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

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

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 engaged in misconduct as demonstrated by video evidence outside the record; and res judicata did not apply to the alleged video evidence. Sutherland claims that the prosecutor’s actions denied Sutherland his constitutionally-protected right to a fair and impartial trial.

{¶ 13} R.C. 2953.21 governs petitions for postconviction relief. R.C.

2953.21(A)(1)(a) provides:

A person in any of the following categories may file a petition in the court that imposed sentence, stating the grounds for relief relied upon, and asking the court to vacate or set aside the judgment or sentence or to grant other appropriate relief:

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

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