A Fairfield County trial court’s decision to conduct one trial for a man accused of committing sex crimes against four young girls over different periods of time was appropriate because the testimony would be simple and direct, and not confuse the jury, the Supreme Court of Ohio ruled today.

In a 6-1 decision, the Supreme Court reinstated the conviction of Jeremy Reed. He pleaded no contest to sex crimes after a judge refused to grant him four separate trials, one for each alleged victim. Reed was sentenced to 28 to 33 years in prison in 2023.

The Court’s decision reversed the Fifth District Court of Appeals, which had vacated Reed’s sentence and ruled he was entitled to separate trials. In a split decision, the appeals court found Reed would not receive a fair trial if a single jury heard the charges regarding all four girls because the jury would improperly consider the testimony of each girl as corroborating the testimony of the others.

Writing for the Court majority, Justice R. Patrick DeWine explained that juries can consider multiple crimes against multiple victims in a single trial if the evidence of each alleged victim is “simple and direct.” If the testimony is uncomplicated and unlikely to confuse the jury, a single trial is permissible, he stated. In his appeal, Reed did not meet his burden to prove that permitting each victim to testify would lead to jury confusion such that he would suffer prejudice from the single trial, the Court ruled.

“Reed did not make any argument before the trial court that the evidence was not simple and direct, or that the jury would not be able to segregate the evidence involving each victim,” Justice DeWine wrote.

Chief Justice Sharon L. Kennedy and Justices Patrick F. Fischer, Joseph T. Deters, Daniel R. Hawkins, and Megan E. Shanahan joined the opinion.

In a dissenting opinion, Justice Jennifer Brunner wrote the appeals court correctly ordered separate trials and questioned how a single trial could be fair. She noted the Fifth District found that the danger of the jury improperly considering the testimony of each victim as bolstering the testimony of the others was significant.

Charges of Abuse Span Across 17 Years
Reed was indicted on 22 criminal counts, including rape of a child under age 13, kidnapping, sexual imposition, and gross sexual imposition. The alleged conduct took place between 2003 and 2020 at times when Reed was romantically involved with the mother or grandmother of each of the victims.

Between 2003 and 2009, Reed abused a girl identified as “T.S.” in court records, beginning when she was 9 years old. He would enter her room in the middle of the night and sexually touch her.

The second and third victims were sisters – G.K. and L.K. Reed abused G.K. between 2014 and 2018, beginning when she was 8 years old. He would come to her bedroom to sexually touch her, and other times he forced her to perform sex acts on him. He also took her on camping trips where he sexually assaulted her.

Between 2016 and 2018, Reed abused L.K, forcing her to perform sex acts on him. Between 2018 and 2020, Reed abused A.M., beginning when she was 7. Reed was involved with A.M.’s grandmother. One night, A.M. went to sleep in the bed her grandmother shared with Reed. The grandmother awoke to find Reed rubbing A.M.’s upper thighs.

Accused Sought Separate Trials
Under the Ohio Rules of Criminal Procedure, an indictment on charges of two or more offenses of a “similar character” can be tried jointly in a single trial. However, under another rule, a trial court must conduct separate trials if it appears “that a defendant or the state is prejudiced by a joinder of offenses.”

Reed asked the court to sever the charges by victim and conduct separate trials for each. Reed did not request a hearing on his motion and offered few specific facts in support of it. He stated that the offenses involved separate victims and occurred at separate times, and did not involve the same incident. He also stated that none of the evidence related to one victim would be admissible to use against him regarding any other victim and that joining the cases would “taint the jurors.”

The Fairfield County Prosecutor’s Office opposed separate trials, arguing the offenses were of the same or similar character. A single trial would conserve judicial resources and prevent the witnesses from having to testify in multiple trials, the office maintained.

The prosecutor also argued the testimony from each victim would be admissible in each of the separate trials as “other acts” evidence. It would show Reed engaged in a pattern, choosing minor female victims he could isolate while living with their mothers or grandmother. The state also maintained a single trial would not be prejudicial to Reed because the evidence was simple and direct, with each victim testifying to her own abuse.

The trial court denied the request for separate trials, agreeing the evidence was simple and direct because the prosecutor would be presenting evidence about each girl, which occurred at different times and involved different acts. The trial judge also indicated the jury would receive a specific instruction requiring that each charge be considered only based on its own evidence, and must not be used to influence its decision on other counts.

Instead of going to trial, Reed pleaded no contest to two amended counts of rape and two counts of gross sexual imposition, and was sentenced to 28 to 33 years in prison.

After Reed successfully appealed the convictions to the Fifth District, the prosecutor appealed the Fifth District's decision to the Supreme Court.

Supreme Court Analyzed Separate Trial Requirements
Justice DeWine explained that under Ohio law the prosecutor could overcome Reed’s claim that he would be prejudiced by a single trial by making one of two showings. It could show either that the evidence of the other crimes would be admissible if the other counts were heard at separate trials. Or it could show that the evidence of each crime was simple and direct.

The opinion explained that Ohio law makes clear that a trial judge can order a single trial if it meets either requirement.

The opinion stated that to receive separate trials, it was Reed’s burden to offer the trial court sufficient information to weigh the decision to join the charges against his right to a fair trial. However, Reed provided little information to the court and did not identify the theories he intended to pursue at trial or specifically indicate any theory of how a single trial harmed him.

Reed’s argument was based on the premise that he would be prejudiced because evidence of one crime might taint the jury in its consideration of others. But the Court explained there is always the possibility of prejudice in joining separate instances in the same case. Reed needed to demonstrate that, based on specific facts of his case, prejudice was likely to occur, the opinion stated. To do this, Reed needed to overcome the prosecutor’s argument that the evidence of each crime was simple and direct.

However, Reed acknowledged that the prosecution’s witnesses and evidence differed for each allegation, and there appeared to be no connection between the allegations, the opinion noted.

“The indictment and the State’s ‘anticipated facts’ to be shown at trial likewise suggest there would have been little danger of jury confusion in a consolidated trial,” the opinion stated.

The offenses related to distinct time periods, some separated by 17 years, the Court noted. The abuse occurred in three different households when Reed was living with three different women. Only the abuse of two sisters occurred in the same home, the opinion stated, and Reed did not explain to the trial court how the expected testimony of the victims would likely lead to juror confusion.

The risk of jurors improperly considering the evidence of one offense as corroborating another could have been minimized by the jury instruction the trial court announced it would give had the case gone to trial, the Court noted.

Based on the limited information Reed provided to the trial court, the Court stated the trial court did not abuse its discretion in ordering a single trial.

Dissent Supported Appeals Court Ruling
In her dissent, Justice Brunner stated the appeals court found the risk of prejudice to Reed was elevated by the “inflammatory nature of the offense,” and the fact that the multiple charges involving multiple victims had the effect of bolstering the claims of each victim.

She wrote the simple and direct test favored Reed’s argument for separate trials. The test focuses on whether a jury is likely to consider evidence of one offense as corroborating the other offenses. The appeals court found that it was likely to occur. She noted the allegations against Reed have clear similarities, and the Fifth District correctly found a jury would have a difficult time avoiding the temptation to respond to the evidence emotionally rather than rationally.

2024-0522. State v. Reed, Slip Opinion No. 2026-Ohio-1174.

View oral argument video of this case.

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