Berea v. Timm

Citations

• 2019 Ohio 2573

Syllabus

Miranda custody Crim.R. 12(C)(3)/motion to suppress sufficiency prejudicial error Crim.R. 16/discovery/witness list domestic violence cumulative-error doctrine. Appellant's initial statement to the police was made prior to appellant being handcuffed and was an admission of physical contact with the victim. Appellant's second statement to the police, made after being handcuffed but prior to being mirandized, was not properly challenged at trial by way of a motion to suppress. The trial court's judgment of guilty was not prejudicial error. Appellant's statement that he threw the victim to the ground was sufficient for a conviction of domestic violence. Appellant was not prejudiced where the trial court allowed testimony from the patrolman that was on the scene the night of the incident. Appellee provided appellant with reports from the incident that included the officer's name and badge number the criminal complaint that was signed by the officer and footage from the officer's body camera. The city did not fail to comply with Crim.R. 16. The cumulative-error doctrine does not apply here. None of appellant's alleged individual errors give cause for reversal.