The Peoples Amicus Curae Brief

IN THE SUPREME COURT OF OHIO TRACIE M. HUNTER, : Case No. 2016-0092 : Appellant, : : : On Appeal from the Hamilton County

vs. : Court of Appeals : First Appellate District STATE OF OHIO, :

: Court of Appeals Case Nos. : C1400684, C140704, C140717

: Appellee. :

AMICUS BRIEF IN SUPPORT OF APPELLANT TRACIE M. HUNTER’S

MEMORANDUM IN SUPPORT OF JURISDICTION ON BEHALF OF AMICI CURIAE

CINCINNATI BRANCH OF THE NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE (“NAACP”), GREATER CINCINNATI

CHAPTER OF THE NATIONAL ACTION NETWORK (“GCCNAN”), THE URBAN LEAGUE OF GREATER CINCINNATI, COALITION FOR A JUST HAMILTON

COUNTY, ET. AL.

Jennifer L. Branch (0038893) Gerhardstein & Branch Co. LPA 432 Walnut Street, Suite 400 Cincinnati, OH 45202 513-621-9100, ext. 13 513-345-5543 (fax) [email protected] Counsel for Amici Curaie Cincinnati Chapter NAACP, et al.

David A. Singleton (0074556) Ohio Justice & Policy Center 215 East 9th Street, Suite 601 Cincinnati, Ohio 45202 Tel.: (513) 421-1108, ext. 17 Fax: (513) 562-3200 e-mail: [email protected]

R. Scott Croswell, III (#019726) Croswell & Adams Co., LPA 1208 Sycamore Street Olde Sycamore Square Cincinnati, Ohio 45202 Phone: (513) 241-5670 Fax: (513) 929-3473

Supreme Court of Ohio Clerk of Court - Filed February 29, 2016 - Case No. 2016-0092

mailto:[email protected]

Counsel for Appellant Tracie Hunter

Merlyn D. Shiverdecker (#0008047) Carr & Shiverdecker 817 Main Street, Suite 2000 Cincinnati, Ohio 45202 Phone: (513) 651-5651 Fax: (513) 345-5565 Mark R. Meterko (#0080992) Karl H. Schneider (#0012881) Maguire & Schneider, LLP 1650 Lake Shore Drive, Suite 150 Columbus, Ohio 43204 Telephone: 614 224-1222 Facsimile: 614-224-1236 Special Prosecutors, State of Ohio Counsel for Appellee

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TABLE OF CONTENTS

EXPLANATION OF WHY THIS CASE IS A CASE OF PUBLIC OR GREAT GENERAL INTEREST……………………………………………………….………...…1

A. DESCRIPTION OF AMICI……………………………………………….…….....2

B. THERE HAS BEEN GENERAL PUBLIC INTEREST IN JUDGE HUNTER’S CASE BECAUSE IT STEMS FROM THE HISTORICAL BATTLE TO ELECT HER AS THE FIRST AFRICAN-AMERICAN JUDGE TO THE HAMILTON COUNTY JUVENILE COURT…………………………………………………....3

C. PUBLIC CONCERN GREW WHEN JUDGE HUNTER FACED RETALIATION

FOR HER ELECTIONS LITIGATION DURING HER FIRST FOURTEEN MONTHS ON THE BENCH……………………………………………………....4

D. THE PROSECUTION OF JUDGE HUNTER UNDERMINDED THE COMMUNITY’S TRUST IN OHIO’S CRIMINAL JUSTICE SYSTEM……………………………………………………………………...……7

CONCLUSION………………………………………………………………………….…13 CERTIFICATE OF SERVICE…………………………………………………………….13

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EXPLANATION OF WHY THIS CASE IS A CASE OF PUBLIC OR GREAT GENERAL INTEREST This brief is filed in support of Judge Hunter’s memorandum in support of jurisdiction on

behalf of Amici Curiae the Cincinnati Branch of the National Association for the Advancement

of Colored People (“NAACP”), Greater Cincinnati Chapter of the National Action Network

(“GCCNAN”), the Urban League of Greater Cincinnati, Coalition For a Just Hamilton County,

other undersigned civil rights organizations, civic organizations, child-advocate organizations,

Jewish, Muslim, Catholic, Ecumenical and Faith-Based organizations, and individuals who are

leaders in the African-American community, advocates for justice, and/or persons of faith.

Collectively, these community leaders and members write to show the Court the great

importance and community interest in this Court accepting jurisdiction over Judge Hunter’s

Appeal.

The historical prosecution of Hamilton County’s only African-American Juvenile Court

Judge, Judge Tracie M. Hunter, has shaken many citizens’ faith in Ohio’s justice system. For

this reason, it is imperative that this honorable Court accept jurisdiction of Judge Hunter’s

appeal. Accepting her appeal, in order to give careful consideration to the constitutional and

important issues raised, would serve a greater goal: it would help to restore public trust in a

justice system that has, in the eyes of Amici, treated Judge Hunter unfairly. As Amici explain

herein, they have perceived the government’s actions against Judge Hunter to be a modern day

Witch Hunt, designed to remove her from the bench after she fought for 18 months just to have

all the votes counted so the true will of the voters would be known. After the votes were

counted, Judge Hunter had to fight for another 18 months the attempts to disrespect her judicial

competence. When that did not dissuade her from doing her job, ten felony charges were filed

against her, nine of which were eventually dismissed. We believe these charges were filed for

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one purpose: to remove her from the bench. It seemed the Special Prosecutor admitted this in

closing argument. This tactic worked, because she has not been on the bench for over two years.

The only remaining charge is a tenuous one involving an allegation about securing a public

contract for her brother who worked for the court for seven years prior to her arrival. Amici

respectfully request that this Court review this single conviction, not only to correct the errors at

trial, but more importantly, to restore Amici’s, and the communities’ confidence in our criminal

justice system.

A. DESCRIPTION OF AMICI

The following membership organizations support this Amicus Brief: Cincinnati Branch

of the National Association for the Advancement of Colored People (“NAACP”); The Urban

League of Greater Cincinnati; Greater Cincinnati Chapter of the National Action Network

(“GCCNAN”); Coalition for a Just Hamilton County; New Prospect Baptist Church; Cincinnati

Improvement Association; World Outreach Christian Church; The Community Church of

Cincinnati; Dominican Sisters of Hope; First Baptist Church; New Vision Missionary Baptist

Church; Joseph Dream, Inc.; Vision Works, Inc.; Word of Deliverance Church; Black Greeks

Speak; Transformation Cincinnati Northern Kentucky; The People's Church; Western Hills

Brethren in Christ Church; Interdenominational National Minister’s Alliance; Tryed Stone New

Beginning Church; Cincinnati District AME Church; Brown Chapel AME Church; St. Stephen

Christ Our Redeemer Church; St Luke AME Church; Bethel AME Church; Lee Chapel AME;

Robert A. Taft High School Alumni Association; the Baptist Minister’s Conference; J-RAB;

Inc.; Kentucky State University Cincinnati Alumni Chapter; Heirs Covenant Church; City

Servants; and Conscious Living Center and several other civil rights, civic, and religious

organizations.

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The following individuals, as well as over 2,100 persons on the attached 188 signature

pages, support this Amicus Brief, including Ohio State Senator Cecil Thomas, President of

GCCNAN; Bishop Bobbie Hilton; Robert Richardson; Joe Mallory; Gwen Robinson; Rev.

Damon Lynch, III, of New Prospect Baptist Church; Rev. Troy Jackson, President of the Amos

Project; and Ford Taylor, President of Transformation-Cincinnati-Northern Kentucky.

B. THERE HAS BEEN GREAT PUBLIC INTEREST IN JUDGE HUNTER’S CASE BECAUSE IT STEMS FROM THE HISTORICAL BATTLE TO ELECT HER AS THE FIRST AFRICAN-AMERICAN JUDGE TO THE HAMILTON COUNTY JUVENILE COURT

One hundred fifteen thousand and one hundred nine (115,109) voters cast ballots to elect

Tracie Hunter Judge of the Hamilton County Court of Common Pleas, Juvenile Division in the

November 2, 2010 election. However, the voters would not know they had elected Tracie

Hunter Judge for over 18 months. The Board of Elections voted not to count over 800

provisional ballots that were cast on Election Day in predominately African-American precincts

in the City of Cincinnati. Without counting these provisional ballots, Tracie Hunter’s opponent,

John Williams, was declared the winner, by 23 votes. Tracie Hunter filed a lawsuit seeking to

have these provisional ballots counted. The case was vehemently defended not only by the

Hamilton County Prosecutor on behalf of the Board of Elections, but also by her opponent, John

Williams, who intervened to side with the Board of Elections to defeat Judge Hunter’s election.

The day after Judge Hunter filed her legal challenge the U.S. District Court issued an Order

requiring the Board of Elections to count the provisional ballots that it had rejected. Hunter v.

Hamilton County Board of Elections, 2010 WL 4878957, SDOH Case No. 1:10-cv-820, Nov. 22,

2010. The Hamilton County Prosecutor and John Williams appealed the initial Order; they

sought to block the provisional ballots from being counted. The Court of Appeals rejected their

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first appeal in January 2011,1 but the Hamilton County Prosecutor and John Williams continued

to fight the Order, eventually forcing a three week trial to be held. In February 2012, the U.S.

District Court again ordered the provisional ballots be counted.2 The defendants filed additional

appeals but the Court of Appeals would not grant a stay of the Order to count the ballots. The

defendants did not stop trying to avoid counting the ballots until finally the U.S. Supreme Court

rejected their petition.3 On May 17, 2012, the Board of Elections, having been forced to count

the provisional ballots, certified Judge Tracie Hunter the winner of the Juvenile Court race.

Judge Hunter won by 74 votes. Judge Hunter is the first African-American Juvenile Court Judge

in Hamilton County history. Her six-year term was reduced to 20 months.

C. PUBLIC CONCERN GREW WHEN JUDGE HUNTER FACED RETALIATION FOR HER ELECTIONS LITIGATION DURING HER FIRST 14 MONTHS ON THE BENCH

Within five months of taking the bench, the Hamilton County Prosecutor (“prosecutor”)

filed a writ of prohibition seeking to prohibit Judge Hunter from ruling on a pending discovery

issue, then quietly dismissed the case.4 At the same time the prosecutor filed a second writ of

prohibition case seeking to stop Judge Hunter from appointing a court administrator, even though

prior judges each had separate court administrators. The prosecutor voluntarily dismissed this

case, too.5 The prosecutor also filed a third writ of prohibition case against Judge Hunter

involving her order to the prosecutor to turn over discovery.6 The case was eventually dismissed

1 Hunter v. Hamilton County Board of Elections, 635 F.3d 219 (6th Cir. 2011) (Hunter I). 2 Hunter v. Hamilton County Board of Elections, 850 F.Supp.2d 575 (SDOH Feb. 2012) (Hunter II). 3 Hamilton Cty. Bd. of Elections v. Hunter, Tracie, SCOTUS Case No. 10A989, issued April 20, 2011. 4 State of Ohio Ex Rel. Hamilton County Prosecutor, Joseph T. Deters, COA Case No. C1200791. 5 State Ex Rel Laura Wickett v. Hunter, COA Case No. C1200694. 6 State of Ohio Ex Rel. Hamilton County Prosecutor, Joseph T. Deters, COA Case No. C130682.

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on the merits.7 These cases filed by the prosecutor started a pattern of lawsuits seeking writs

filed against Judge Hunter in her official capacity as Juvenile Court Judge. In all, five suits were

also filed by the media8 and 18 writs of procedendo suits were filed by the public defender.9

Most of the media cases filed against her were eventually dismissed or resolved in her favor. It

seemed that every week there was another media report about one or more of these cases filed

against Judge Hunter. But when she won her case or it was dismissed there was no media

coverage. This left the impression with the public that Judge Hunter was under siege by the

prosecutor, public defender, and media.

Judge Hunter was unable to defend herself in the media based on the judicial rules of

conduct. Nor was she permitted to defend herself in the First District Court of Appeals. These

suits filed against Judge Hunter all needed outside counsel to defend her because representation

by the Prosecutor created a conflict of interest if not an appearance of impropriety. How could

the prosecutors properly defend Judge Hunter when they had sued her, was still appealing the

ongoing elections case,10 and was the subject of grievances filed by Judge Hunter based on their

7 State of Ohio Ex Rel. Hamilton County Prosecutor, Joseph T. Deters, COA Case No. C130682. 8 Judge Hunter won one case (State Ex Rel The Cincinnati Enquirer vs. Hunter, COA Case No. C1300397, Entry denying writ dated October 16, 2013); one case was voluntarily dismissed (State Ex Rel The Cincinnati Enquirer vs. Hunter, COA Case No. C1300759); and two appeals were dismissed as moot by this Court (State Ex Rel The Cincinnati Enquirer vs. Kissinger, Ohio Supreme Court Case No. 2013-1694, State Ex Rel Scripps Media Inc. DBA WCPO TV v. Hunter, Ohio Supreme Court Case No. 2014-52); and one case was dismissed while Judge Hunter’s motion to hear the case on the merits and to vacate the contempt order was pending (State Ex Rel The Cincinnati Enquirer vs. Hunter, COA Case No. C130183). 9 Seven of these writ of procedendo cases were voluntarily dismissed and the remaining eleven cases were eventually dismissed by this Court after Judge Hunter’s compliance with the writs mooted her merits appeals. See Ohio Supreme Court Case Nos. 2013-1725, 2013-1726, 2013-1727, 2013-1729, 2013-1733, 2013-1734, 2013-1831, 2013-1832, 2013-1834, 2013-1835, 2013-1836. 10 Hunter v. Board of Elections remained pending after Judge Hunter was certified the winner of the election. Both the Board of Elections and John Williams prosecuted their appeals until they

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conduct on cases?11 Over her written objection, the Hamilton County Prosecutor attempted to

represent Judge Hunter, but based on their handling of those cases, she had pro bono counsel

defend her in one of the media cases. The First District sua sponte struck her pro bono counsel’s

pleadings and notice of appearance.12 With no representation on the case, she filed answers pro

se in her judicial capacity to defend the cases. Again, the First District sua sponte struck her

pleadings.13

In 11 of the 18 writ of procedendo cases two outside counsel were eventually appointed.

However, these lawyers were not independent of the prosecutor’s office: they were personally

recommended by Prosecutor Joe Deters14 and one made campaign contributions to his political

campaign.15 Judge Hunter requested new counsel but her request was denied.16 They never

defended Judge Hunter. Their inaction caused the First District to issue 11 judgments against

Judge Hunter when those lawyers failed to answer any of the complaints. If they had defended it

would have been a matter of public record that Judge Hunter had the highest caseload of any

Juvenile Court Judge in Ohio, according to reports released by this Court, and had the highest

caseload of both Juvenile Judges in Hamilton County, with over 100 more objection hearings

scheduled on her docket than Judge Williams.17 Had the 11 writ cases filed against Judge

were dismissed on July 12, 2012. In addition, Judge Hunters’ attorneys’ motion for attorney fees was pending until November 2013. 11 See State Ex. 21, Hamilton County Prosecutor Deter’s application for appointment of counsel whom he chose. 12 State ex rel. Scripps Media, Inc. v. Hunter, COA No. 120241, Entry dated May 10, 2013. 13 State ex rel. The Cincinnati Enquirer, COA No. C130072, Entry dated June 3, 2013. 14 See Ohio v. Hunter Case No. B1400110, State Ex. 21. 15 See Deters for Ohio’s Future 2012 campaign finance reports. 16 See Ohio v. Hunter Case No. B1400110, State Ex. 24 and 25. 17 See Merits Briefs and Supplements filed in Ohio Supreme Court Case Nos. 2013-1725, 2013-1726, 2013-1727, 2013-1729, 2013-1733, 2013-1734, 2013-1831, 2013-1832, 2013-1834, 2013-1835, 2013-1836. These appeals were eventually dismissed by this Court as moot because Judge Hunter had already issued the rulings.

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Hunter been answered, it would have demonstrated that the majority of those cases were not

delayed, but were well within the established guidelines, especially since some of those cases

had been pending long before Judge Hunter took over the case.

This inability by Judge Hunter to defend herself and the ceaseless prosecutor’s attacks

fueled the media’s relentless negative portrayal of her as she diligently worked to implement

rehabilitative policies and procedures in the Hamilton County juvenile court system, such as

unshackling children and exploring new training initiatives to reduce injury to employees and

children and reduce gun related offenses. Her efforts to institute juvenile reform came to a head

when Judge Hunter was accused of crimes by the people who fought to keep her out of her

Judgeship. Having watched the efforts to keep her off the bench and then to unseat her, we saw

injustice occurring. We Amici, members of our organizations, and our friends and family were

unable to stop the massacre of Judge Hunter. We had faith in the justice system after the federal

courts ordered the provisional ballots be counted, even though that took 18 months. But after

this unending onslaught of cases against Judge Hunter in the state court, where she was literally

left defenseless, weakened our faith in the justice system. The public’s trust of the Ohio justice

system deteriorated further when the media reported in September 2013, that Judge Hunter was

being investigated for unexplained crimes after only 14 months on the bench, while she was still

acclimating to her new judgeship.

D. THE PROSECTUION OF JUDGE HUNTER UNDERMINED THE COMMUNITY’S TRUST IN OHIO’S CRIMINAL JUSTICE SYSTEM

The media reported in September 2013 that a grand jury was being convened to

investigate allegations made by the Hamilton County Prosecutor that Judge Hunter had

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“backdated” entries in order to prohibit the prosecutor from appealing her rulings.18 These

charges were eventually dismissed. The Prosecutor Deters had a conflict of interest in pursuing

these charges so he requested R. Scott Crosswell and Merlyn Shiverdecker be appointed as

special prosecutors. The Common Pleas court approved his request.19 Amici did not perceive

these two special prosecutors as independent. They were recommended by Prosecutor Deters;

they defended Deters when he was being investigated by a special prosecutor for a theft from the

property room and when Deters was Treasurer and his office was accused of misconduct’20

Croswell’s law partner21 represented Deters in his divorce; and Croswell and Shiverdecker

contributed to Deters’ political campaigns.22 The special prosecutor’s actions were repeatedly

challenged in a motion to dismiss for prosecutorial vindictiveness.23

The most recent and disturbing concern about the prosecution of Judge Hunter did not

surface until January 13, 2016 when Judge Hunter filed a Motion To Dismiss Counts 1 - 4 For

Violating Her Due Process Rights To A Fair Trail By Destroying Exculpatory Computer

Evidence.24 The motion challenges the State’s failure to preserve Brady exculpatory evidence.

Counts 1 – 4 involved two court entries Judge Hunter’s case manager entered on the docket

using dates that were different than the date the Judge signed each entries. Judge Hunter was

18 See Ohio v. Hunter Case No. B1400110, Ex. ZZ prosecutor Breyer’s memorandum to prosecutor Deters. 19 See Stipulation of Judge Beth Myers, Ohio v. Hunter , Case No. B1400110, T.p. V. 29 at 3368-3369. 20 See Ohio v. Hunter, Case No. B1400110, Defendant’s Motion to Dismiss Indictment dated June 3, 2014 and http://www.cincinnati.com/story/news/2014/06/03/hunter-dismiss-charges-due-joe-deters/9927213/ 21 R. Scott Croswell’s firm is Croswell & Adams Co. LPA. 22 See Ohio v. Hunter, Case No. B1400110, Defendant’s Motion to Dismiss Indictment dated June 3, 2014 23 See Ohio v. Hunter, Case No. B1400110, Defendant’s Motion to Dismiss Indictment dated June 3, 2014 and argued on June 25, 2014 and December 14, 2015. 24 See Ohio v. Hunter, Case No. B1400110, Defendant’s Motion to Dismiss Indictment filed January 13, 2016.

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charged with 4 felonies over these two entries. The jury could not reach a verdict on these 4

charges. Before the re-trial, Judge Hunter’s new counsel conducted discovery and learned that

the two computers used by the case manager had not been preserved and one was wiped clean

and sold after the grand jury subpoenaed material from it but before the indictment was made

public. The State new that the computers used to create the two entries were material evidence.

Both the Deter’s office and the special prosecutors knew since August 2013 that computers were

once used by the case manager, not Judge Hunter. The motion accused the State of acting in bad

faith when it failed to preserve this exculpatory evidence; yet, the State never disputed the

allegations in the motion. Instead, on the morning of the retrial, the State dismissed these four

felonies, along with the five remaining felonies.

Prosecutor Joe Deters’ bias was palpable. In a radio interview with a local radio host of a

highly rated program in August 2013, Deters expressed anger that Judge Hunter filed an ethics

complaint against him and said that he wanted the Ohio Supreme Court to remove Judge Hunter

from the bench.25 He then orchestrated a press conference26 on the eve of the first trial, blaming

Judge Hunter for the tragic shootings of two children. Every major media outlet widely

circulated stories of Joe Deters accusing Judge Hunter of murder. The banner headline for one

report read “Deters: Tracie Hunter rulings resulted in 2 deaths.” His inflammatory remarks were

widely reported in the 4 days before jury selection began, clearly tainting the jury pool.

The substituted trial judge, Judge Dinkelacker, also appeared biased. While Judge

Hunter’s affidavit of disqualification was denied by this Court,27 additional issues became

25 http://www.700wlw.com/media/podcast-bill-cunningham-bill_cunningham/joe-deters-82713-hour-2-23639353/ 26 http://www.cincinnati.com/story/news/courts/2014/09/04/deters-hints-tracie-hunter-rulings-deadly/15040145/ 27 Ohio v. Hunter, Supreme Court Case No. 15-AP-084, Judgment Entry dated October 20, 2015.

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known that exposed how unfair it was for Judge Dinkelacker to preside over this case. First, the

prosecution planned to use as State Exhibit 22 at trial which is a contempt order Judge

Dinkelacker, a former First District judge, issued against Judge Hunter.28 The prosecutors also

planned to quote from State Ex. 44, which is an order by Judge Dinkelacker dismissing the

prosecutors appeal in a juvenile delinquency case, where Judge Dinkelacker gratuitously wrote

for the First District dicta, chastising Judge Hunter: “once again, this judge, has followed a

pattern of completely ignoring the statutory mandates and rules of procedure.” They read this

sentence to the jury in closing argument. T.p. at 3543 (V. 30). Furthermore, the prosecution

intended to introduce State Exhibits 7, 9, and 11, all of which are opinions by Judge Dinkelacker

issuing writs of procedendo against Judge Hunter. To have the presiding trials judge’s orders of

contempt, disparaging remarks, and writs given to the jury, as they were in the first trial, would

cause unfair prejudice against Judge Hunter and further defeat her right to a fair trial.

Even the foreperson was biased. After trial it was revealed that the foreperson of the jury

withheld her bias against pastors. As a teenager she had been sexually abused by her youth

minster for three years. She did not truthfully answer the court’s jury questionnaire or respond to

counsel’s questions. The foreperson spoke and wrote publicly about her distrust of clergy and

religion. She knew that Judge Hunter is a pastor; hence her concealment of her pastoral bias was

a material and prejudicial. Had she revealed her bias she would have been struck by defense

counsel. When this was revealed in a fully documented motion for new trial,29 the court denied

it. Denial of the new trial further eroded the communities’ trust in the criminal justice system.

Appellate Courts are expected to remedy errors made in the trial court. But in this case

the appeals process was unfair because the issues and arguments Judge Hunter could raise on

28 Ohio v. Hunter, Case No. B1400110, State Ex. 22. 29 Ohio v. Hunter , Case No. B1400110, Motion for New Trial field 11-17-14.

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appeal were restricted by the First District’s refusal to remove the case from the accelerated

calendar. The First District eventually did remove the case from the accelerated document but

that was done only for the purpose of publishing its decision. The severe page limit and the

inability to reply to the prosecutor’s arguments hamstrung the defense from presenting the best

possible appeal. For example, there were 51 instances of prosecutorial misconduct during the

brutal four hour closing argument, including making inflammatory remarks, interjecting personal

opinion, citing unsworn testimony, asking the jury to draw negative inferences from uncalled

witnesses and impugning the defense – the cumulative effect of which denied Judge Hunter a fair

trial. Judge Hunter was relegated to attaching a summary instead of arguing them fully before

the court.30 For example, the prosecutor stated, without any evidence in the record for support:

Maybe what Deters has to listen to is the social worker who says this child is being sexually abused and we can't get this child out of the home because we can't get Judge Hunter to rule on the case.

T.p. at 3816 (V. 31). Despite a vehement objection, the court did not strike this statement and

properly instruct the jury. The Court’s acceptance of allowing this lie emboldened the

prosecutor to repeat it at T.p. at 3814, 3857.

The First District’s release of its opinion on the Friday before the second trial created a

media frenzy and served to further prejudice the potential jurors against Judge Hunter. Judge

Hunter repeatedly requested a motion for change of venue due to the enormous negative media

attention inundating the jury pool. She filed 1,500 pages of newspaper reports with reader

comments, television reports, radio reports, blogs, and twitter posts.31 The first trial was

broadcast live and live blogged. The First District’s release of its opinion the Friday before the

30 Ohio v Hunter, COA 1400684, Appellate Brief Appendix B, filed July 24, 2015. 31 Ohio v. Hunter, Case No. B1400110, motion for change of venue filed April 3, 2014 and supplements filed on December 18, 2015, December 22, 2015, and Jan. 19, 2016 and exhibits submitted at hearings on December 14, 2015 and December 22, 2015.

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second trial fed this media frenzy. Its release only 11 days after oral argument also created

suspicion that the decision was a rush to judgment merely to give the special prosecutors an

affirmed conviction to help them in their next prosecution.

Finally, it cannot be emphasized enough that the 9 dismissed felonies were never proven;

yet they lingered, hanging over Judge Hunter’s head, and reported in the media for almost 2.5

years. The eventual dismissal of the charges received minimal press coverage. These concerns

of delay in dismissing the charges, the jury and judge bias, prosecutorial vindictiveness,

destruction of exculpatory evidence, and the prosecutorial misconduct have caused Amici and

the community to have grave concerns that Judge Hunter was treated unjustly.

The reason Judge Hunter was treated so unfairly was revealed in the special prosecutor’s

closing argument when he misled the jury by claiming he did not want Judge Hunter to go to jail.

And I could tell you and I could give you my solemn oath and my word as a professional that if, if she is convicted of these charges I would be the last person to ask anyone to incarcerate her. That's not where I come from and that's not what it's about. Not to me.

T.p. at 3799. Yet, he requested “that a substantial prison sentence should be imposed” during

sentencing.32 What the prosecution wanted was a conviction in order to remove Judge Hunter

from the bench. By the time the criminal case is over it will have cost Hamilton County

taxpayers almost $2,000,000 to keep Judge Hunter off the bench.33 Half of that number is slated

to pay the special prosecutors recommended by Deters. This waste of tax payer dollars is even

more egregious when the Ohio Attorney General’s Office of Special Prosecutors could have

handled the case for free. This is calculated, prolonged, wasteful, malicious prosecution is

32 Ohio v. Hunter, Case No. B1400110, prosecutor’s sentencing memorandum filed Dec. 4 2014. 33 Because the prosecutor unsuccessfully defended the elections civil rights case it paid the attorneys who brought that case over $850,000 in fees and expenses. The County has paid the special prosecutors $650,000 for work done through September 4, 2015 and has reserved another $500,000 to pay their remaining bills.

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nothing more than an outrage. It shows the community that justice is not only out of reach for

Judge Hunter, but for all African-Americans in Hamilton County who have fewer resources and

supporters than Judge Hunter.

In order to restore voters’ faith their elected officials will serve a full term, and

confidence in Ohio’s criminal justice system, we Amici Curaie urge this Court to accept Judge

Hunter’s appeal and give her arguments careful consideration.

CONCLUSION If a Judge cannot receive a fair trial in Hamilton County, Ohio, how can the citizens of

this community including Amici, our membership, our family, our friends, our fellow

congregants have any hope there will be justice if they become involved in the criminal justice

system? For the sake of our community, justice, and fairness we respectfully request this Court

grant Judge Hunter’s petition to have her appeal heard by this Court.

ADDENDUM

The attached 188 pages contain the names of the over 2,147 Amici Organizations and

individuals on whose behalf this Amici Curiae Brief is filed.

Respectfully submitted,

/s Jennifer L. Branch Jennifer L. Branch (0038893) GERHARDSTEIN & BRANCH CO. LPA 432 Walnut Street, Suite 400 Cincinnati, Ohio 45202 (513) 621-9100 (513) 345-5543 fax [email protected] Counsel for Amici Curiae Cincinnati Chapter NAACP, et al.


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CERTIFICATE OF SERVICE

I hereby that the foregoing pleading was served on all counsel by U.S. Mail First Class

and by fax on February 29, 2016:

Counsel for Appellant Tracie Hunter: David A. Singleton (0074556) Ohio Justice & Policy Center 215 East 9th Street, Suite 601 Cincinnati, Ohio 45202 Tel.: (513) 421-1108, ext. 17 Fax: (513) 562-3200 e-mail: [email protected]

Counsel for Appellee State of Ohio, Special Prosecutors R. Scott Croswell, III (#019726) Croswell & Adams Co., LPA 1208 Sycamore Street Olde Sycamore Square Cincinnati, Ohio 45202 Phone: (513) 241-5670 Fax: (513) 929-3473 Merlyn D. Shiverdecker (#0008047) Carr & Shiverdecker 817 Main Street, Suite 2000 Cincinnati, Ohio 45202 Phone: (513) 651-5651 Fax: (513) 345-5565 Mark R. Meterko (#0080992) Karl H. Schneider (#0012881) Maguire & Schneider, LLP 1650 Lake Shore Drive, Suite 150 Columbus, Ohio 43204 Telephone: 614 224-1222 Facsimile: 614-224-1236

/s Jennifer L. Branch Jennifer L. Branch #0038893


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u ~r

...{""") '--

r OF APPELLANT JUDGE TRACIE M. HUNTER ~ v AMICUS BRIEF IN SUPPORT OF JURISDICTION

,.S° ON BEHALF OF AMICI CURIAE i_ CINCINNATI BRANCH OF THE NATIONAL ASSOCIATION FOR THE

~ ADV AN CEMENT OF COLORED PEOPLE ("NAACP"), GREATER CINCINNATI

CHAPTER OF THE NATIONAL ACTION NETWORK ("GCCNAN"), THE URBAN ', - LEAGUE OF GREATER CINCINNATI, COALITION FORA JUST HAMILTON

\~ ~

,'---...__ ...... .,

COUNTY, ET. AL.

I hereby provide my signature as representation that I support the Amicus Brief in /\

supportofjuri~ .-~ //ii. L ~ /If . r/ /?.L rx ~ v~- -

Sighature ~ Signathte L {A_, I r.V ~Name: b t-rl ~ h~ \\3--0'Wl L\S Print Name: et) /lfl c:0- ~- F::J

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Signature PrintName: ~ _ _ .

0172

AMICUS BRIEF IN SUPPORT OF JURISDICTION OF APPELLANT JUDGE TRACIE M. HUNTER

ON BEHALF OF AMICI CURIAE CINCINNATI BRANCH OF THE NATIONAL ASSOCIATION FOR THE

ADVANCEMENT OF COLORED PEOPLE ("NAACP"), GREATER CINCINNATI CHAPTER OF THE NATIONAL ACTION NETWORK ("GCCNAN"), THE URBAN

LEAGUE OF GREATER CINCINNATI, COALITION FOR A JUST HAMILTON COUNTY, ET. AL.

I hereby provide my signature as representation that I support the Amicus Brief in support of jurisdiction.

~~1< ~"\ - ------- - - -----, Signature PrintNa~e: D<:f2... e k R_Agnrv /) / ,I /1 ,:J

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Si?Tiature ,/) / 0 •·-"'l , ( Pnnt Name: K ~ h .J r-f t /.,o \j · f._ =-- . I r l ?jJ/J?J2.~1 I rx··JM--t1- ,

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Signature ' ___ /) ___ _ ,M ~' ' ~-· I PrintName: \ · i\\\U::"V .N -~ (:_;:;. Ii

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0173




LEAGUE OF GREATER CINCINNATI., COALITION FOR A JUST HAMILTON COUNTY, ET. AL.

ature as representation that I support the Amicus Brief in

Signature ~ PrintName: "/1~

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Signature

J;fr[~~'.:-:J~~-~~~~-sfgnahireCI-_' .

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0174

1,

AMICUS BRIEF IN SUPPORT OF .IDRISDICTION OF APPELLANT JUDGE TRACIE M. HUNTER

ON BEHALF OF AMICI ClJ!llAE CINCTh"'NATI BRANC11 OF THE NATIONALASSOCIATIDN FOR THE

ADVA.'iCE~'T OF COLORED PEOPLE ("NAACP"), GREATER CINC~'NATI CHAPTER OF THE NATIONALACTION NETWORK (~CN~""), THE URBAN

LEAGUE OF GREATER CINCINNATI, COALITION FORAJUSTHAI\ULTON C-Ol.JN~ ET. AL.

I hereby provide my si~ as ~tion tba1 I support the~Bri:ef m

~~ ~ ~~ Si~. J,,. Si .... e V1 r \,; PrintName<J A-fH.... If/ ty(c/1//tf:.~~ame: ~ \-~k, l'-

~(!l(J~ Si;zffe/ ~= PrlntNome:Uuo/ fl/P,Aer PrimName: T__t'b 1f+'L-1>1.-J

0J.___ Ma~ ~ (J;1(;/ffa t /U =-™"' e.11"'" tt ~o.\<ry, ~<:<r v "W!e;UJ;]J? ~- ~·- ~v~ I ~ ~ ~~ TL.r.t ~-~

~~;;rJ~ 1::,~;:ERT ~~/ ~ ~-~~~~

Signature /) ~ ( l I Print Name; J/Q n I Y:; e W '5

ree ~~. :ame: ~a. C Kock-~~~

0175


ONBEHALFOFAMICICURIAE CINCINNATI BRANCH OF THE NATIONAL ASSOCIATION FOR THE


LEAGUE OF GREATER CINCINNATI, COALITION FORA JUST HAMILTON COUNTY, ET. AL.

Si~ture \; j , ,-cTu PrintName:fJ:>one V(f~ e

e-/1rl\ (A~ - t\Jh~ Si~ ;; {). /!/ PnntName: \tfl~> ~O-;-~/C?~

~~ .. ~aeLe Sigilatitre- -ir; · Slgllature _ PrintName: 'Vlon;criJE'\ N'-\-Ui\bet. PrintName: 5@/1///!J f?Jft&.-f /

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0176





Signature V Print Name: e. a... ~ t5c,

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Signature ,-.j /"""\ / ) Print Name:(,41..(.J;Jla(\t!u) 1 JJ

' sjlltJYa J rv1 Ai ' • i-- -i:. ~ I,---,,..; I f • -._;:--v:_ v_y~ rA _____ ,,..._. -------

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il\hi_vl<_u~~~ . ~~~ P12 Signature _ S1gnafur'e'l'f'/UC'.3e...s' ~ Print Name: )v't6n"D<lf\ uTun,~/ ~ Print Name: kr~s~NV\d&- Aile.A

(_, ')~~ .e!L?.Pz:; f!jJ Signature ~ 1~ ,, Signature / -0 _ (d. Print Name: luftllA~~{ Print Name: ·/!31<., l c:.__ i::::o t:A..J

~i7~±::: Signature Print Name: -------

7:e~~ .bi~ be.o~u@L rx)~ ~A-f~- J Signature Print Name: --------

0177



ADVANCEMENT OF COLORED PEOPLE (''NAACP"), GREATER CINCINNATI CHAPTER OF THE NATIONAL ACTION NETWORK ("GCCNAN"), THE URBAN

LEAGUE OF GREATER CINCINNATI, COALITION FOR A JUST HAMIL TON COUNTY, ET. AL.

I hereby provide my signature as representation that I support the Amicus Brief in support of jurisdiction.

I

~111· ef~ Signature PrintName: Susa..n {YI. Mkr

'1nC1~~ Y\.J1ms Signature u-· t. I · , Print Name: JlMjO J~cl ~

J) ( C',uu,,;A if~r71k/A~ Signature I · ·· ~ _ Print Name: /IJ a r· , ~ f>-e.. 9",r>~

Vl~~ti/L---Signature' .-Print Name: MGfZ€L'/N l3/rri's-t./lirv1s-

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~/JWYY-~ />116 ~~ Signature . a ) Print Name: /rl 11 A1 , (:f L , b go vi N

k~ Ct-~ Signature;~-./ ,.... --:Pr (' Print Name:O ){ f I / ·fl 1J (!) 11(_

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Signatufe U c>"

Print Name: ---------

Signature Print Name:

~~~~~~~~~~~-

0178



ADV AN CEMENT OF COLORED PEOPLE ("NAACP"), GREATER CINCINNATI CHAPTER OF THE NATIONAL ACTION NETWORK ("GCCNAN"), THE URBAN


I hereby provide my signature as representation that I suppog the Amicus Brief in

supporto~jurisdic~ia ~ ./)/ ~· !~. 0 __ /ff ~--

(.//{~ .· /li ~ ---·- . · ,,ature , 1 \/\,\(_~I sfgnature - !' 1 /1 I i

Print Name: J_, f Y) e:lO--- /Vt GVIPfr IL- Print Name: I ()_ vd cJI If}/; l I l1 /~ y~ I .

~!L~no ~~~~--=-~ Signature I' _jJ . ,\ Print Name: Be:Je: le.1. L. ~-h/inc, j. Uo/,\Jc::-// =y-: l -~ I J

Signature £., , 1 J • Print Name: I i V!-1 o-t--L., H o.J ... )J-ho VVIC I ~

~ !. J~~VVy ~0--~~ Siglnature ' ,,- '. , Si~ . _ ~ __ . PrintName: '3t:55 EC.. Hll "t/1/-f bi?/l>E PrintName:SA DYE"' B µeA V' ~ o~ /l . I /J 1 /l . ~ ~·LS:~

Signature . Print Nie: AV\ a e,,,\ SM ·1 +H

-.4·~ 73.~LJ Signature _ 1 B, I Print Name: ..Tu R-/") I rv "1 ts_

SignatUre ~ · - : B 1 11 /

PrintName: Mi ti 11/1 EA f c£w1/

cr1~·~~~ Signature . _ - /\ 11 I\ I" Print Name: La U I St: l: VfVf<.'V_:::7 .

~;(/( if!h~ 4#1~ cL~=-Signature Q 13· Signature · PrintN~4 HJ <~!lo v J.P:S Print Name: !-J.,#' f-f/o /f(L f111Jflr/l,

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- v. '"'f rv I - • ~I I PrintName:nJ flu~/ ( f:: !OB

0179





I hereby provide my signature as representation that I support the Amicus Brief in

sf(jW@uriCio~~ c?~u~/;j_ ~~ S!gnature l v , } • -· "

PrintName:/\nnt~ M c)/ I 1-> u~ .. ,~,,u~. I....,, If"/ l)>C,Jl\J./. I ,L_f .' JC -'Of

Signature Print Name: _. . . ·~ . _

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)(--" \ - /J /1 UC\ I " j' ef1/(/ . P-lt_---' "-~~-=-~~/-' !--------"- /~ Ll'.HIZ~~ Signature~~~ k?. . Signature r' . ~ 11 .

~rintN e:_!:t'.Rel< I ~RReSS.' PrintN"'.:'e:~ ~ca ,w, ' I 1>-n-f'

~-°C~412r&dd ~ !~ -F -- · 1gna e Signature . - ,,t

Print Name: PrintName:O rfre-1 t ;4 D e,~L) h'\.

~" rr ~ , r . . ~ ---? ' '1 ! v ~ s ·'-....r-~ j) L:-~ ~ ~\ >sL ~"'-t{ .. ~ Si?natlfre \~I '4 5 -- A' r ,,._ Si~ature C' /. I -=t;.~r\ - ' Pnnt Name: / "'" C~~ --- Pnnt Name: = 6(...Q_,.. J-::X 'hl S 01"-

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Sigl(J.ature , / ,... Print Name: N ciA/A BCc..JIJ ~KA '/11 '-t. l"'>t1t\_

0180





I hereby provide my signature as represenration that I support the Amicus Brief in

su~:j~~ ( v(j_~ ~ 0t(l)l Signature - A I Print Name: /llV/Nk/e__ r-trcne t=

.. fl a..<:&"~\ '-. Ol..~

&~ -;!, htt: Signature 1 •

Print Name: Dv I? I s L '\ s e fJ 71 tW1V\ -e:,{ v, toJ (et.

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01 ~7- ---

Print Name: '-¥\J\r\f~ l ut:bS Pri~tName: fll!.-1..!--I L ~'--JL!

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Print Name: fZ.e.7/IU; If) 'f !-(CJ[ .-u; K Print Name:-\' 'DSV\a__ \r{1( µ& V \S

~~ ~ ~~~~--7#~~----'b'-------SiatUT1 Sign= ' . ·

Prind e: ~~Ii, PIDJName:U;/,'lJ_;1. <J-f-e-e/E !W '1>1-~~ ·. /rry~_ &/l~

Signature · ~igllature PrintName::J)dha M. R-e.ndeL PrintName: Jf4WBJ1.i};J,at? _,

~ ~ <J~/z_~~~ s~ -~// t/ // Si~a~ure - / 111 .LL L, I I

PnntName: "f/'/Lic/;j1£/ rt:lc..A.JUe7;- PnntName:Lo (~ /\ll.l (0-)~ ~ //~ /\ . ·1 ~ oz-~ ~~ill!A( j,~_J'i Signature-/;;~ _/.'J - Signature) U- 'CY'_ , l\ PrintName:L~~r/'~~r-/ PrintName: \ \DfAV\iCM ~,lanes

. / - - ,7 ....

I

Lols--fn. tJ~ 0181






support of jurisdi~oJL ~ (\ .

'~d£! ~~'t)~--Signature t!J " J S~ature , _ .- . ~ . PrintName:. AM1 ~ t-...13~owr/P'dntName:C~&/,5+1N e-- .u1cJ..-etLsv/O

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.0/0t~ JJ,dfa-vt~ Sa,~ c~<)s Sigi'iahife _ }'\ . . (1 . Signature Q _ c,,. n , Print Name~ tJ /(_ l~ th. din e-l4-1r Print Name: 00/Gln 00S..)

G~ ~~ . ·OlltV~hl GAA-un1, Signature /) _ rQ Signatur~7 Print Name': 1' ~ E'.- LA- V R D A1J ,vf}-X. ~Name: fYl ccr d lfX\ l:1;" d u.J l

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Signature rL ( s A Ii ~tna~ure - ' - J . -Print Name: .J l\ A'\..d,A C V\\ &§it Name: I t>..N.l4,~~ ~2' DD ,.. 1 • l # t;\f) ~ '\

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Print Name: r~1~ 2'~ \ria ~ ~ \I ,(2,~f' ~ ~ -Si-1-gu_a_tur_e______,,=------=--

Print Name: L.A'R.R'/ :f?Rok:}.N · PrintName: :v. __ ·=:--v• 1

0182

0183

0184

0185

0186

AMICUS BRIEF IN SUPPORT OF JURISDICTION

OF APPELLANT JUDGE TRACIE M. HUNTER

ON BEHALF OF AMICI CURIAE

CINCINNATI BRANCH OF THE NATIONAL ASSOCIATION FOR THE

ADVANCEMENT OF COLORED PEOPLE (“NAACP”), GREATER CINCINNATI

CHAPTER OF THE NATIONAL ACTION NETWORK (“GCCNAN”), THE URBAN

LEAGUE OF GREATER CINCINNATI, COALITION FOR A JUST HAMILTON

COUNTY, ET. AL.


support of jurisdiction.

___________________________________

Signature

Print Name: TROY JACKSON, Director, The

AMOS Project______________

___________________________________

Signature

Print Name: __________________________

0187

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

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Signature

Print Name: __________________________

0188

Documents

The Peoples Amicus Curae Brief