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State v. Brown
Citations: 508 N.E.2d 1030; 31 Ohio App. 3d 86; 31 Ohio B. 128; 1986 Ohio App. LEXIS 10118Docket: No. C-850402
Court: Ohio Court of Appeals; December 9, 1986; Ohio; State Appellate Court
The appeal involves Debra Denise Brown, indicted by the Hamilton County Grand Jury on five counts, including two counts of aggravated murder with death penalty specifications. A jury convicted her of both aggravated murder counts and other charges while finding her not guilty of the death penalty specifications. Brown was sentenced to life in prison without parole for twenty years and additional consecutive terms of ten to twenty-five years. The case stems from a July 13, 1984, incident where Brown and co-defendant Alton Coleman entered the home of Marlene and Harry Walters under false pretenses, ultimately robbing and assaulting them, resulting in Marlene's death and Harry's severe injuries. Brown's appeal includes a claim that the trial court erred by denying her motion for a joint trial with Coleman. The court found that, under R.C. 2945.20, when jointly indicted for a capital offense, defendants are entitled to separate trials unless a joint trial is granted for good cause, which must be shown by the requesting party. Brown's interpretation that the statute allows for a waivable right to a joint trial was rejected, as the court emphasized that a motion for a joint trial requires judicial approval based on the discretion of the trial court. Brown's reasons for seeking a joint trial—her desire to be tried with Coleman and her counsel's belief that it was necessary for adequate case preparation—were not considered sufficient to demonstrate "good cause," as defined by precedent, which requires factors not typically present in similar cases. Brown did not claim that her representation was inadequate due to her separate trial or that this separation prejudiced her rights. The court reviewed the trial court's decision, considering the arguments made and the lack of prejudicial effect from the separate trial, concluding that the trial court acted within its discretion in denying a joint trial with Alton Coleman. In her second assignment of error, Brown argued that the trial court improperly allowed the state to call witnesses unrelated to her case, but the court disagreed. The state presented eight witnesses who provided testimony on other acts committed by Brown and Coleman, detailing their methods of entry and robbery of victims. This evidence demonstrated a pattern of conduct and was deemed admissible under Evid. R. 404(B) and R.C. 2945.59, as it was relevant to establishing motive, intent, and other pertinent factors. The probative value of this evidence outweighed any potential unfair prejudice. Consequently, the second assignment of error was found to lack merit, and the court affirmed the lower court's judgment, noting only Brown's claim of being denied the right to waive her separate trial was previously addressed.