State v. Crawford

Citation2022 Ohio 1509
Decision Date10 May 2022
Docket Number2020-0797
PartiesThe State of Ohio, Appellee, v. Crawford, Appellant.
CourtUnited States State Supreme Court of Ohio

Submitted May 11, 2021

Appeal from the Court of Appeals for Cuyahoga County, No. 108431 2020-Ohio-2939.

Michael C. O'Malley, Cuyahoga County Prosecuting Attorney, and Gregory Ochocki, Assistant Prosecuting Attorney, for appellee.

Mark A. Stanton, Cuyahoga County Public Defender, and Jeffrey M Gamso, Assistant Public Defender, for appellant.

Dave Yost, Ohio Attorney General, Benjamin M. Flowers, Solicitor General, and Samuel C. Peterson, Deputy Solicitor General, urging affirmance for amicus curiae, the Ohio Attorney General.

DeWine, J.

{¶ 1} Late one night, a heated argument among a group of partygoers spiraled out of control, culminating in a fatal shooting. Despite some differing testimony, we know that Jeremy Crawford fired his gun at the scene. Crawford committed a felony when he fired his gun, because he was under disability as a result of a prior, unrelated drug offense that prohibited him from having or using a firearm.

{¶ 2} Following a jury trial, Crawford was convicted of involuntary manslaughter. Under Ohio law, a person may be found guilty of involuntary manslaughter if he causes the death of another as a proximate result of committing another felony. R.C. 2903.04(A). Here, Crawford's weapons-while-under-disability offense served as the predicate felony for his involuntary-manslaughter conviction.

{¶ 3} Crawford challenges the involuntary-manslaughter conviction. The challenge he raises is a legal one. Crawford does not argue that there was insufficient evidence for the jury to find that his gun use caused Dickens's death. Rather, he argues that as a matter of law, his involuntary-manslaughter conviction is improper because his prior drug offense that formed the basis for his firearms disability was unrelated to the victim's death. In other words, Crawford asks us to hold that for a weapons-while-under-disability crime to serve as a predicate offense for an involuntary-manslaughter conviction the reason for the disability must be causally related to the victim's death.

{¶ 4} We find no basis for reading the involuntary-manslaughter statute in the manner Crawford suggests. By its plain terms, R.C. 2903.04(A) simply requires that one cause the death of another "as a proximate result" of the commission of a felony. Thus, we affirm the judgment of the court of appeals, which upheld Crawford's conviction.

I. BACKGROUND
A. The night of the shooting

{¶ 5} Dickens was killed as the result of gunshot wounds that he suffered after a late-night party in Cleveland turned into an altercation that spilled out into the street. Testimony introduced at Crawford's trial provides some details about what took place.

{¶ 6} According to witnesses, Crawford showed up at the party to meet up with his then-girlfriend Cassandra. The party mostly featured a small group of Cassandra's and Crawford's family members, though accompanying Crawford was a man unfamiliar to the other partygoers-a man whom Crawford called "Prince."

{¶ 7} Most in attendance were either drunk or high on cocaine and ecstasy, or both. When Crawford arrived at the party, he was confronted by one of Cassandra's relatives who was not fond of Crawford. Dickens quickly went up to face Crawford as well. These two had something of a history-one prior run-in started with a fight and ended with Dickens knocking Crawford out. So, when Dickens told Crawford he'd "beat his ass like he did before," things at the party really started to get heated. By this time the group had moved outside and the situation continued to get worse. At some point, Crawford pulled his gun and fired multiple shots into the air.

{¶ 8} There was conflicting testimony on whether Crawford fired the shots that killed Dickens. At trial, one partygoer claimed she saw Prince fire the fatal shots, and another witness said he heard gunshots shortly after he saw Prince walk up to Dickens. Others said they never saw Prince with a gun.

{¶ 9} The state also called a witness who had not been at the party but who had seen Crawford several days after the party: the ex-girlfriend of Crawford's half-brother. According to her, the couple picked up Crawford after he called his half-brother about a flat tire. While the witness and Crawford were in the car together, Crawford allegedly told her that he brought a gun with him to the party because he knew Dickens would be there, that he shot and killed Dickens during their fight, and that he hit a curb when leaving the scene, damaging his car tire in his getaway. The same witness testified that the next day Crawford told her that "he wanted people to know that he shot into the air" and that it was Prince who fired the fatal shots. The witness didn't believe Crawford, testifying, "I already knew that it wasn't true because he told me the other story."

B. Crawford appeals following his conviction

{¶ 10} Crawford was indicted on four felony counts: (1) discharging a firearm on or near prohibited premises under R.C. 2923.162(A)(3); (2) felony murder under R.C. 2903.02(B), with the unlawful-discharge-of-a-firearm offense serving as the predicate felony offense; (3) having a weapon while under disability under R.C. 2923.13(A)(3); and (4) involuntary manslaughter under R.C. 2903.04(A), with the weapons-while-under-disability offense serving as the predicate felony offense.

{¶ 11} The jury came back with guilty verdicts on the weapons-while-under-disability and involuntary-manslaughter counts. It also found him guilty of the unlawful-discharge-of-a-firearm charge, but because there was "no finding of causing serious physical harm," the court reduced that offense from a felony to a misdemeanor. The jury found Crawford not guilty of felony murder.

{¶ 12} Crawford appealed to the Eighth District Court of Appeals, raising two assignments of error, only one of which is relevant to this appeal. In his first assignment of error, Crawford asserted that the crime of having a weapon while under disability cannot, as a matter of law, be the underlying proximate cause of a death. He reasoned that the crime of having a weapon while under disability is generally a possession crime and that mere possession of a firearm cannot cause injury. The court of appeals rejected this argument, noting that R.C. 2923.13(A)(3) covers more than just possession: the statute makes it a crime for a prohibited person to "knowingly acquire, have, carry or use" a firearm. 2020-Ohio-2939, ¶ 39. Although the jury verdict did not specify the exact manner in which Crawford violated the statute, the court found "substantial evidence that Crawford [had] used the firearm," with "[multiple eyewitnesses testifying] that Crawford brought a weapon to [the] house, brandished the gun, and fired the gun." Id. And while acknowledging that the evidence did "not make it definitively clear who shot and killed Dickens," the court found that when viewing the evidence in the light most favorable to the state, there was sufficient evidence to support the jury's finding that Dickens's death was the proximate result of Crawford's having violated the statute. Id. at ¶ 40. Crawford appealed, and we accepted jurisdiction. 160 Ohio St.3d 1415, 2020-Ohio-4612, 154 N.E.3d 91.

II. ANALYSIS

{¶ 13} Crawford's appeal to this court relates solely to his conviction for involuntary manslaughter. We accepted jurisdiction over the following proposition of law:

Having a weapon under a disability cannot, in the ordinary course of things, serve as the predicate offense to involuntary manslaughter.
In his briefing, Crawford elaborated on what he means by this proposition:
The statutory predicate offense in this case was not that Mr. Crawford "did knowingly acquire, have, carry, or use" the weapon. * * * Rather, the offense was doing one of those things while under a disability due to a prior charge or conviction of attempted drug possession. The plain meaning of the statute, captured effectively by its title, is that the gravamen of the offense is the disability due to the attempted drug possession. What necessarily follows is that for death to be a proximate result of having a weapon under a disability due to the drug offense, that disability is not a mere quibble. It must be necessary to the proximate result.
The question then becomes whether the disability due to attempted drug possession has any causal relationship to the death.

(Emphasis deleted.) Thus, in Crawford's view it is not enough that a death be caused by a violation of the weapons-while-under-disability statute, instead, the death must be related to the "circumstance under which the activity was criminal (that Mr. Crawford had previously been convicted of attempted drug possession)." By this logic, Crawford's felony offense of using a firearm while under disability could not have served as the predicate offense for involuntary manslaughter, because his prior drug offense did not cause Dickens's death.

A. There is no requirement that the reason for a disability be causally connected to the victim's death

{¶ 14} We need look no further than the plain terms of the involuntary-manslaughter statute to assess Crawford's argument. R.C. 2903.04(A) provides that "[n]o person shall cause the death of another * * * as a proximate result of the offender's committing or attempting to commit a felony." The statute requires two things for an involuntary-manslaughter conviction: (1) that a felony was committed and (2) that a person's death was a proximate result of the commission of that felony. Nothing in the statute requires any connection between the reason for the disability and the death of the victim.

{¶ 15} In referencing the ...

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