State of Ohio v. Adam Bowers, Case No. 2019-1282
First District Court of Appeals (Hamilton County)
- Does a court engage in unconstitutional fact-finding when it finds that force was used during the rape of a child under 10?
- Does a court that sentences an offender to a term of 25 years to life for a conviction of raping a child under the age of 10 need to make an express finding of force when the record contains evidence of force?