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Court News Ohio
Court News Ohio

Death Sentence Upheld for Man Who Suffocated Victim

Image of death-row inmate James Worley.

Death-row inmate James Worley.

Image of death-row inmate James Worley.

Death-row inmate James Worley.

The Ohio Supreme Court today affirmed the death penalty imposed on James Worley for the 2016 murder of a 20-year-old girl he bound and suffocated.

In a unanimous opinion, the Supreme Court rejected Worley’s appeal of the murder conviction and sentence for the death of Sierah Joughin, including his contention that jury selection in Fulton County and the trial itself was tainted by revelations of a similar attack of a woman by him in 1990.

Writing for the Court, Justice Michael P. Donnelly stated that Worley’s murder of Joughin was not a crime of impulse. He wrote that Worley had spent significant time, including on the day of the offense, watching pornographic videos showing young women being bound and strangled, and that Worley was resolved to murder Joughin to escape detection for kidnapping her.

Woman Goes Missing While Biking Home
Joughin lived on County Road 6 in rural Fulton County. Her boyfriend, Joshuah Kolanski, lived nearby on County Road 12. Joughin rode her bicycle to Kolanski’s home. Around 6:45 p.m., she left to ride back home. Kolanski, on his motorcycle traveling to visit a friend, followed her part of the way. He recorded two videos of Joughin as she rode home.

About 45 minutes later, a motorist noticed a bicycle lying on the side of the road and saw a man who was two or three rows deep in a cornfield bent over at the waist.

When Joughin did not return home, Kolanski and Joughin’s mother started to search for her and called the police. Shortly after 7 p.m. a farmer noticed a motorcycle helmet on the side of County Road 6 and picked it up. After hearing about police activity on the road, he turned the helmet over to law enforcement. The helmet had reddish-brown stains that testing later indicated was blood.

Later that evening a Fulton County Sheriff’s Office deputy located Joughin’s bike in the cornfield and found motorcycle tire tracks and a box of fuses in the area. A further search of the area discovered other items, including a pair of men’s sunglasses and an orange-handled screwdriver.

Motorcyclist Investigated
Two days later, law enforcement officers went to Worley’s property on County Road 6 to interview him. He told officers that he was riding his motorcycle around 6 p.m. on the day Joughin went missing, and that his motorcycle stalled out. He noticed two bicycles lying on the ground near a cornfield and pulled his motorcycle into the cornfield and out of view from the road because he was going to ride one of the bikes home. He then decided against it and rode his motorcycle home. He said he did not see anyone on his trip. He told officers that when his motorcycle broke down, he lost his helmet, fuses, a screwdriver, and sunglasses.

Worley initially let investigators walk around his property, but did not allow a thorough search. He was told that security video from the Evergreen High School complex on County Road 6 showed a motorcycle traveling on the road between his property and where Joughin went missing. He initially insisted that he was not on County Road 6 at that time, but later admitted he had not told officers the truth.

A search warrant for his property revealed Worley had a crate in his barn that concealed adult diapers, bondage clothing and restraints, latex gloves, clear plastic bags containing women’s lingerie, rope, and a sex toy. They also found his motorcycle, which had weeds stuck to it, handcuff keys, two sets of handcuffs, a zip tie, and a bottle of bleach. Police located women’s pink underwear with stains that tested positive for blood.

Searcher Discovered Body
One of the volunteers searching for Joughin noticed a disturbed area of the cornfield. It appeared that something had been dragged for about 20 to 25 yards. Investigators found Joughin’s body covered in dirt with her wrists handcuffed behind her back. She was dressed in a lace bra, handcuffs, a rope, and an adult diaper. A rubber cone-shaped dog toy, which was secured with a shoelace tied at the back of her head, had been used to gag her.

An autopsy revealed a head wound caused significant bleeding and could have been caused by being struck with a motorcycled helmet. The medical examiner found the dog toy filled Joughin’s oral cavity and that one of her teeth was broken. The examiner indicated the toy was stuffed in Joughin’s mouth with enough force that it could have broken her tooth and that she suffocated to death about 10 minutes after the toy was inserted.

Motorcyclist Charged With Murder
Worley was indicted by a grand jury on 19 felony counts, including two counts of aggravated murder and kidnapping. The indictment included the charge of purposely causing Joughin’s death while “committing or attempting to commit” kidnapping. Each aggravated murder count included two death-penalty specifications. One specification alleged that Worley committed the murder in the course of a kidnapping. The other alleged that the purpose of the murder was to escape “detection, apprehension, trial, or punishment” for the kidnapping.

During the trial, the Fulton County prosecutor asked the trial court to dismiss two charges, and Worley was convicted on all other counts. The prosecutor elected to seek the death penalty based on an aggravated murder charge with the specification that Worley was attempting to escape detection. The jury recommended the death sentence, and the trial court imposed it. Worley also received a sentence of 25 years and 11 months in prison for the other crimes.

A death penalty conviction triggers an automatic appeal to the Supreme Court of Ohio.

Report of Previous Abduction Submitted at Trial
At Worley’s trial, Robin Gardner testified about her encounter with Worley in July 1990. Gardner was 26 years old at the time and was riding her bike in a rural area of Lucas County. As she was nearing her house, she was struck from behind by a pickup truck.

The driver, later identified as Worley, asked her if she was OK and then struck her on the back of her head with a hammer and put her in a stranglehold. He held a screwdriver to her throat and threatened to kill her if she did not get into his truck. Worley forced Gardner into the truck, then attempted to handcuff her hands behind her back, but he was only able to cuff one wrist. A motorcyclist spotted the struggle and stopped to help Gardner. She was able to get out, and the motorcyclist drove her home. Worley was convicted of abduction.

In his appeal, Worley argued that his right to a fair trial had been violated because prospective jury members were exposed to information harmful to him and helpful to the government.

The trial court had drawn a pool of 400 prospective jurors and granted Worley’s request to have each prospective juror questioned on the topics of pretrial publicity and the death penalty. The court dismissed 156 prospective jurors during pretrial hearings, and the remaining prospects were interviewed over the course of two days. Several individuals were dismissed because they knew Worley or Joughin or members of their families. At one point, a prospective juror stated she could not be impartial “based on that he did this 30 years ago.” The judge interrupted her and told the prospective jurors to answer specific questions and avoid making additional comments.

Worley’s attorney asked the judge to the dismiss the entire panel of more than 200 and start again with a new panel of jurors. The attorney argued the reference to Worley’s prior conviction tainted the entire panel. The prosecution objected, stating that Worley’s attorney agreed Gardner would be testifying about the incident. The judge warned prospective jurors that only information produced during the trial could be considered and to disregard statements made during jury selection.

The next day, one of the prospects wanted to be excused because he had made up his mind. He lived about three miles from Worley, who the potential juror said “attended our church after his imprisonment 25 years ago.” The juror was dismissed, and Worley’s attorney again asked for the entire jury selection process to be restarted.

Justice Donnelly wrote that the Court will not presume that jury selection is tainted when a prospective juror makes improper comments during voir dire. The opinion noted that the trial court gave instructions to the jurors to rely solely on the evidence submitted at trial, and those selected asserted they could be impartial. The Court noted none of the perspective jurors who referred to Worley’s past conviction were selected. The Court denied Worley’s claim that the trial court abused its discretion by denying the request for a new jury panel.

Testimony of Prior Charge Unfair, Accused Asserted
Worley also argued the introduction of Gardner’s testimony was inadmissible “other acts” evidence that prejudiced the jury.

The Court explained that evidence of other acts can be admitted for a limited purpose, including proof of “motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.” The prosecutor argued it was presenting Gardner’s testimony to prove “identity,” because Worley was disputing that he was the perpetrator. The Court ruled that “his identity was squarely at issue.”

The opinion noted that Gardner’s testimony demonstrated Worley’s “modus operandi,” which is described as evidence of “signature, fingerprint-like characteristics unique enough” to show crimes were committed by the same person. In both cases, Worley assaulted a young woman riding a bike on a rural road surrounded by cornfields, hitting them on the head, causing skull fractures. In both crimes, he used a distinctive type of handcuff on the victim that could not be removed with keys available to law enforcement.

The Court stated the “most powerful evidence of modus operandi” was the use of a screwdriver during the abduction. While Worley argued his screwdriver was not found near Joughin’s abduction site and could not be admitted as evidence, the Court said its location did not bar it from being admitted, but that it was up to the jury to decide its relevance based on the tool’s location.

“The similarities between Worley’s abduction of Gardner and the evidence of his kidnapping and assault of Joughin are striking,” the opinion stated. “Indeed, the trial court correctly determined that Gardner’s testimony was offered for a proper purpose — i.e., to prove the identity of Joughin’s killer,” the opinion stated.

The Supreme Court also rejected Worley’s nine other legal claims contesting his conviction and sentence.

The Court additionally conducted an independent analysis of the aggravating circumstances
that led to the convictions and mitigating factors to determine if the death penalty was properly imposed. The Court concluded the death penalty was appropriate.

2018-0757. State v. Worley, Slip Opinion No. 2021-Ohio-2207.

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