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Ohio Case Law

State v. Carter-El, 2025-Ohio-4842

Case Information

Court: Court of Appeals of Ohio Eighth Appellate District County of Cuyahoga
Date: 2025-10-23
Citation: 2025-Ohio-4842
Read the Opinion

Summary

Summary: Defendant-Appellant, a juvenile at the time of the offense, was convicted of aggravated murder, felonious assault, and related firearm specifications stemming from a fatal shooting during an attempted robbery. The appellate court affirmed the convictions and sentence, finding sufficient evidence and proper consideration of the defendant’s age under statutory and constitutional sentencing requirements.

Key Holdings

  • Sufficient evidence supported the aggravated murder conviction including video identification eyewitness testimony and DNA evidence
  • The trial court properly considered the defendant’s age and associated mitigating factors under R.C. 2929.19 when imposing sentence
  • Manifest weight of the evidence supported the jury’s verdict based on corroborated eyewitness testimony and forensic evidence
  • Mandatory bindover from juvenile court was appropriate where probable cause and statutory requirements under R.C. 2152.10 and 2152.12 were met

More Information

The case arose from a fatal shooting that occurred outside In & Out Beverage in Cleveland, Ohio, where three individuals allegedly attempted to rob a man and subsequently shot him. Defendant-Appellant, a juvenile at the time, was identified through surveillance video, DNA evidence from the getaway vehicle, and testimony from a cooperating co-defendant. The juvenile court held a bindover hearing and, finding probable cause, transferred the case to adult court under mandatory bindover provisions.

At trial, the State presented extensive evidence, including video footage showing three individuals approaching and shooting the victim, forensic links between the Defendant and the vehicle, and detailed testimony from a co-defendant who identified Defendant as a shooter. The defense challenged the sufficiency and weight of the evidence, particularly the credibility of the co-defendant. However, the jury convicted Defendant on multiple counts, and the court imposed a sentence of 36 years to life, with parole eligibility after 25 years due to his juvenile status.

On appeal, Defendant raised four assignments of error: insufficiency and manifest weight of the evidence, improper sentencing that failed to weigh youth as a mitigating factor, and error in the juvenile court’s bindover decision. The appellate court overruled all assignments. It held that the evidence, including corroborated testimony and video, was sufficient and credible. It also concluded that the sentencing court complied with R.C. 2929.19’s mandate to consider youth-related factors and that the mandatory bindover was legally supported by credible evidence and probable cause.

This case reinforces that juvenile offenders can be subject to adult court jurisdiction and severe penalties when statutory bindover criteria are satisfied and proper procedural safeguards are followed. The decision underscores the importance of a thorough record demonstrating that youth-related sentencing factors were meaningfully considered.