Highland Hills v. Safford

Citations

• 2026 Ohio 456

Syllabus

Codified ordinances; minor misdemeanor; right to counsel; venue; plain error; R.C. 2901.12; Ohio Const., art. X, § 12; manifest weight of the evidence. Appellant's conviction for a violation of Village of Highland Hills Cod.Ord. 331.08 was not against the manifest weight of the evidence. Appellant was not entitled to assigned counsel because he was cited with a minor misdemeanor and the right to counsel does not apply to minor misdemeanors that have no possibility of jail time. Appellant did not challenge venue at the trial court level; therefore, we review appellant's claim that the city did not establish venue for plain error. We find no plain error — venue was clearly established by witness testimony.