Death-row inmate Lance Hundley

Death-row inmate Lance Hundley

The Ohio Supreme Court today affirmed the conviction and death sentence of a Youngstown man who murdered a disabled woman he briefly lived with, then tried to kill her mother, and set them both on fire.

A Supreme Court majority rejected the claim of Lance Hundley that there was insufficient evidence to convict him of the November 2015 murder of Erika Huff, the attempted murder of her mother, and arson. Writing for the Court, Justice Sharon L. Kennedy stated that “Huff’s death was the result of a well-thought-out plan and the attack was drawn out.”

Chief Justice Maureen O’Connor and Justices Judith L. French, Patrick F. Fischer, R. Patrick DeWine, and Melody J. Stewart joined the opinion. Justice Michael P. Donnelly concurred in judgment only.

Acquaintance Moves In
Huff had a progressive form of multiple sclerosis and could no longer walk. She used a wheelchair to move around, had a lift to assist her into bed, received daily care from nursing aides, and wore a medical-alert necklace that was monitored by a medical response company.  If the alert was activated, the company would call Huff’s mother and also dispatch an ambulance to Huff’s address.

Hundley had recently moved from Washington D.C., and been living with his brother. Hundley’s brother had a child with Huff, and Hundley said he knew Huff for about eight years. Hundley asked Huff if he could stay at her house and she agreed.

On Nov. 5, 2015, A’Shawntay Heard, a nurse’s aide, helped Huff get into bed at the end of her shift. At Huff’s request, Heard placed the cash from Huff’s monthly disability check underneath her thighs, between the bedsheet and Huff’s body.  She gave Huff her personal phone number, which was against company policy, because Heard felt that “something was going to happen.” Heard said Hundley had been in and out of the house all day and was making her feel uncomfortable.

Emergency Responders Alerted
At 2:01 a.m. the next morning, Huff’s medical alert necklace was activated and an ambulance was dispatched to Huff’s home. Emergency medical technicians responded. A man, one EMT later identified as Hundley, opened the front door and told her the alarm was accidentally triggered and there was nothing wrong. The ambulance squad left.

The medical response company also called Huff’s mother, Denise Johnson. When she arrived, she found Hundley standing in the home with a gasoline can, and asked Hundley where Huff was. Johnson picked up the gasoline can and took it to the garage.  Upon re-entering the house, Hundley attacked her, and hit her repeatedly with a hammer.

During the attack, Hundley told Johnson he killed Huff. Hundley also grabbed a kitchen knife and held it to Johnson’s face while choking her.  Johnson lost consciousness and when she regained consciousness, she was lying on the floor in Huff’s bedroom next to her daughter. Johnson could see flames burning at her feet and around Huff’s body, which she tried to brush away.  She attempted to escape through a window by dislodging an air-conditioning unit.

Husband, Police Arrive
Johnson’s husband drove to the house and called 911 just before 3 a.m. Youngstown police arrived and heard Johnson scream for help.  Once the police pulled Johnson to safety, they noticed Huff’s body. Officers entered the house three times, but twice had to retreat because of heavy smoke.  The third time they entered the home they found Hundley lying on the floor near the front door, hiding halfway underneath the dining-room table. Hundley and Johnson were transported to a local hospital for treatment. Johnson sustained multiple significant injuries and told police Hundley attacked her.

After reviewing the autopsy report, the medical examiner concluded that Huff died from “two mechanisms,” -- blunt trauma to her head and body and strangulation with a cord. The examiner concluded she died before the fire was ignited and that the blows to her body were not immediately fatal. The blunt-force trauma was leading to “massive internal bleeding around her belly,” and contributed to her death in conjunction with the strangulation.

Finger Pointed at Unknown Intruder
At the hospital, police took Hundley into custody and he told police he and Huff had a good relationship. He said he had been at a local bar and had a few drinks before returning to Huff’s home. He claimed he had been “choked out” by a stranger who broke into Huff’s home, and Hundley denied killing her.

A grand jury indicted Hundley on five counts: aggravated murder with prior calculation and design; attempted murder; felonious assault; and two counts of aggravated arson. The aggravated murder charge included a death-penalty specification.

Hundley pleaded not guilty to all counts.

The prosecution presented DNA evidence linking Hundley to the murder as well as finding gasoline on the clothes he was wearing when the fire in the house started. Johnson testified, as did police and fire investigators.

Hundley said he returned to the home from a local bar around 11:30 p.m. and talked to Huff before he went to sleep on the living room couch. He testified the next thing he remembered “was being woke up with somebody strangling [him] out from behind.” He said he blacked out and woke up on the kitchen floor. He said he then saw a dark-skinned black male about his height leaving Huff’s bedroom carrying a gasoline can.

He said he saw  Johnson with the gasoline can and the intruder sitting in Johnson’s husband’s truck. He said he began to hit Johnson with a hammer because he “didn’t know what she was going to do from that point.”

The jury deliberated for less than four hours before convicting Hundley on all charges. Hundley then fired his attorneys and represented himself at a mitigation phase of the trial. The prosecution presented into evidence most of the exhibits from the guilt phase of the trial . Handley did not present any mitigating evidence.

The jury recommended a death sentence based on aggravated murder by prior calculation and design. The trial judge imposed the death sentence and, as to the noncapital offenses, sentenced Hundley to 22 years in prison for the attempted murder and arson charges.

Offender Appeals Conviction
In his automatic appeal to the Supreme Court, Hundley raised 10 arguments, known as propositions of law. Among them, he argued the prosecution failed to prove beyond a reasonable doubt that he committed the murder with prior calculation and design, which allowed for the death penalty.

Justice Kennedy explained when there is a claim of lack of sufficient evidence, the Court must determine if “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” To demonstrate prior calculation and design, the justices used three factors to guide them that are outlined in the Court’s 1997 State v. Taylor decision.

The Court determines: Whether the accused and victim knew each other and, if so, was that relationship strained?; did the accused give thought or preparation into choosing the murder weapon or murder site?; and was the act “drawn out” or “an almost instantaneous eruptions of events”?

The Court ruled that the prosecution provided sufficient evidence to support all three Taylor factors.

First, while Hundley testified that he and Huff had a good relationship, Huff’s mother and nurse’s aide Heard both testified the relationship was strained and Huff’s demeanor changed after Hundley moved in. It was up to the jury to consider the credibility of Hundley’s version of his relationship with Huff compared to the contradicting version from Johnson and Heard.   From Heard’s and Johnson’s testimony the jury could reasonably conclude the relationship was strained, the opinion stated.  It was concern for Huff’s welfare that caused Heard to violate her employer’s policy and provide Huff with her cell-phone number.   Additionally, the jury could have inferred that Huff did not trust Hundley because she had Heard place her cash under her thigh when Heard left for the evening.

Next,  Hundley acknowledged that Huff was severely disabled, unable to walk or dress herself, and needed help getting into bed.

“The jury reasonably could have found that Hundley gave thought to the murder site and to the means by which he would kill Huff. Hundley waited until the nurse’s aide had left for the evening and Huff was alone before returning to the house. He knew that Huff was unable to defend herself and that she was helpless. She was debilitated by multiple sclerosis and depended upon an aide for the essentials of daily living, including using a lift to get from her bed to her wheelchair, which she relied on for mobility. The medical-alert necklace was her sole lifeline in the event of an emergency when the nurse aide was not at the house ,” the Court wrote.

The Court determined Huff’s murder was drawn out. The Court noted the medical examiner’s testimony showed that Hundley inflicted a lengthy, severe beating to Huff, who tried to fend off the attack.

“Huff was still alive after the savage beating but instead of stopping, Hundley made the conscious choice to strangle her tightly around the neck with a black cord. The nature and extent of the injuries established that Huff’s murder was not immediate but was carried out over a period of time.” The court noted that Hundley could have chosen to abandon his course of action at any point but failed to do so.

Court Determined Sentence Warranted
The Court conducted its independent review to determine if the evidence supported the jury finding that the aggravating circumstances outweighed the mitigating factors to justify a death sentence.  While Hundley did not present mitigating factors at his trial, the Court examined reports from psychologists who interviewed Hundley. The experts concluded he did not suffer from a mental illness, and the Court found no other factors that would lead to the mitigating factors outweighing the aggravated circumstances.

The Court also explored whether the death sentence in this case was proportionate to other sentences imposed on other defendants for similar crimes, and concluded the penalty was appropriate.

2018-0901. State v. Hundley, Slip Opinion No. 2020-Ohio-3775.

View oral argument video of this case.

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