State v. Rogers

Summary

The Ohio Supreme Court affirmed the Twelfth District Court of Appeals’ judgment, holding that Rogers failed to demonstrate that juror McCarthy was actually biased and therefore could not prevail on his ineffective‑assistance claim. The Court further held that a reviewing court may consider both individual and group answers in voir dire when assessing actual bias, and that an individual juror’s explicit affirmation of impartiality is not required. Consequently, the appellate court’s reliance on group answers was proper and no new rule was created.