Court News Ohio
Court News Ohio
Court News Ohio

Court Upholds Woman’s Life Sentence for Conspiring to Kill Informant

The Ohio Supreme Court today affirmed the life sentence of a Cuyahoga County woman who conspired to murder a police informant and was complicit in the acts leading to his death.

A Supreme Court majority affirmed the conviction of Sheila McFarland for her role in the death of Robert Williams, 64. Williams was shot to death in the hallway of the Indian Hills Senior Community Apartments in Euclid in November 2015.

Ryan Motley shot Williams. He was an associate of McFarland’s and her boyfriend, Eddie Brownlee. Through a plea bargain, Motley is serving 18 years to life in prison . McFarland and Brownlee were arrested on drug charges  based on information Williams had provided to police. McFarland and Brownlee were accused of directing Motley to harm Williams, and Motley said he shot Williams because he believed Williams was reaching for a gun.

In the Court’s lead opinion, Justice Sharon L. Kennedy wrote that McFarland was a central figure in the killing of Williams. She was a constant presence in the discussions to target Williams for revenge, the plans to kill him, and the meetings with the assailants after he was killed, the opinion stated.

Justice R. Patrick DeWine concurred in Justice Kennedy’s opinion.

Chief Justice Maureen O’Connor and Justices Judith L. French and Patrick F. Fischer concurred in judgment only.

Tenth District Court of Appeals Judge Julia L. Dorrian, sitting for Justice Melody J. Stewart, concurred in the Court’s ruling regarding McFarland’s conviction for aggravated murder, aggravated burglary, and kidnapping.

Justice Michael P. Donnelly dissented, noting that some of the biggest threats to the public’s  confidence in the justice system are wrongful convictions, disparate treatment, and sentences that are inconsistent with criminal culpability, and he found that this case fits the bill for all.  Justice Donnelly determined there was insufficient evidence to sustain McFarland’s convictions.  Judge Dorrian joined Justice Donnelly’s dissent regarding McFarland’s conviction for conspiracy.

Arrests Leads to Revenge Plot
Williams lived with his girlfriend Korri Henderson at the Indian Hills senior complex. After police caught Williams selling drugs there, he and Henderson agreed to become confidential informants and provide information about their drug supplier, Brownlee.

With Williams’ help, Brownlee and McFarland were both arrested for selling drugs. McFarland was  released from jail, but Brownlee was kept there. The couple almost immediately suspected Williams was responsible for their arrest. Brownlee and McFarland spoke numerous times by phone while he was in jail, and she was using Brownlee’s cellphone. 

In one call, Brownlee said about Williams that he was going to “get him.” Motley was with McFarland at the time when Brownlee called. Brownlee told Motley during the call that “I need you to handle this.” On that same call, Brownlee asked McFarland what happened to a gun he owned, and McFarland told him that Motley had already retrieved it from a hotel where Brownlee and McFarland were staying. The gun was eventually used to kill Williams.

While Brownlee was in jail, Motley and McFarland sold drugs together to raise money to bail out Brownlee. During that time, McFarland called Williams and Henderson twice and accused them of working with police and “being snitches.”

Murder Occurs after Release
On Nov. 10, 2015, Brownlee was released from jail and he and McFarland almost immediately went back to selling drugs. On Nov. 12, McFarland warned a customer of Brownlee that Williams and Henderson were snitching. Brownlee met with Motley in the hotel where he and McFarland were staying.

Brownlee discussed with Motley what to do about Williams. Motley said Brownlee told him to “go rough the dude up, beat him up.”  Henderson, Williams’ girlfriend, said the night before Williams was killed that Brownlee called Williams and told him the two “were going to see their graves.” Henderson said McFarland called her in the early morning hours of November 14 from Brownlee’s phone. McFarland denied Brownlee was making threatening phone calls.

Later that morning, Motley along with his brother Raymond and Rahkee Young sneaked into the apartment complex and hid in the stairwell at the end of Williams’ hall. After a brief confrontation, Motley shot Williams and the three men fled. Motley said that after the murder, he and his two accomplices met with Brownlee and McFarland at the couple’s hotel room.  Motley received $4,000 worth of drugs as payment for the murder.

Woman Contests Murder Charges
Brownlee, McFarland, Ryan and Raymond Motley, and Young were all indicted on the same 10 counts, including aggravated murder and conspiracy to commit aggravated murder. Each of the 10 counts included a firearm specification.

McFarland’s case was tried before a jury . At the conclusion of the Cuyahoga County prosecutor’s  case, McFarland’s lawyer asked for the charges to be dismissed , arguing the state failed to present sufficient evidence to establish that McFarland was guilty of the 10 charges against her. The trial judge denied the request, and a jury found her guilty on all charges.

McFarland was sentenced to life in prison without parole, along with three concurrent 11-year sentences and three years for the gun specification. She was also fined $20,000.

McFarland appealed her convictions and sentence to the Eighth District Court of Appeals, which affirmed the convictions but found some errors with her sentencing regarding one of the aggravated murder charges and a kidnapping charge.

McFarland appealed the Eighth District’s decision to the Supreme Court, which agreed to hear the case.

Court Weighs the Evidence
Justice Kennedy explained the Supreme Court’s role in this appeal was to determine whether the evidence was sufficient to support the jury verdict. Reviewing the sufficiency of the evidence requires the Court to examine the evidence admitted at trial to determine whether such evidence, if believed, would convince an average person’s mind of the defendant’s guilt beyond a reasonable doubt.

“The relevant inquiry is whether, after viewing the evidence in a light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a reasonable doubt," the lead opinion stated.   

Because McFarland was not present at the shooting, the central issue was whether the state proved that McFarland was complicit in the commission of the crimes, the lead opinion stated. R.C. 2923.03, Ohio’s complicity law, makes it a crime to “aid or abet another” in committing an offense or to “conspire with another” to commit an offense. Anyone who violates the complicity law “shall be prosecuted and punished as if he were the principal offender,” the opinion noted.

McFarland was prosecuted as if she were the principal offender, and “the evidence at trial was sufficient to prove that McFarland was complicit in the crimes associated with killing of Williams,” the Court concluded.

Dissent Finds Manifest Injustice
In his dissent, Justice Donnelly noted that Motley confessed to the murder in exchange for a plea agreement, which resulted in an 18 years-to-life sentence. Motley was the key witness in McFarland’s trial, and he agreed that if his testimony was not truthful and consistent with other known facts, the state could rescind his plea agreement.

Motley repeatedly stated that McFarland had no participatory role in the crimes perpetuated by Brownlee, Motley and Motley’s accomplices. The dissent stated that because Motley’s testimony  exonerates McFarland from the charges,  the Court needed to search the record to uphold McFarland’s convictions, but came up empty-handed.  The dissent picked apart each piece of evidence relied on by the court to demonstrate McFarland did not have any involvement in the crimes.

The dissent found despite the paucity of evidence, McFarland was convicted.  By exercising her constitutional right to trial, she turned down a plea agreement that could have resulted in three-year sentence.  She also turned down another plea deal, offered while the jury was deliberating.  Instead, she was convicted and ended up with the most severe sentence short of the death penalty—life without the possibility of parole—while Motley, who pulled the trigger and killed the victim, has the opportunity to be released in 18 years, the dissent stated.

“Sheila McFarland chose to place her trust in the criminal justice system, and it failed her, allowing a conviction to stand based not on evidence but on innuendo, speculation, and conjecture.  This court—provided with a final opportunity to remedy this injustice—perpetuates the failure,” Justice Donnelly stated.

2018-1116. State v. McFarland, Slip Opinion No. 2020-Ohio-3343.

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