Miles v. Cleveland Clinic Health Sys. E. Region

Citations

• 2025 Ohio 5628

Syllabus

Removal of juror for cause; R.C. 2313.17; fair, impartial, and unbiased juror; voir dire; conflicting statements; defer to trial court; Batson challenge; exclusion of expert medical testimony; motion in limine; proffer; preserve for review on appeal; irrelevant evidence; inadmissible; unfairly prejudicial. Where the record shows the defendants-appellees established the existence of facts showing a potential juror's inability to serve as a fair, impartial, and unbiased juror, the trial court did not abuse its discretion when it granted defense counsel's motion to excuse the juror for cause. The trial court did not abuse its discretion in denying plaintiff-appellant's motion to excuse potential jurors for cause because the jurors indicated they could be fair, impartial, and unbiased. This court defers to the trial court's assessment of any contradictory statements by the jurors, relying on the prospective jurors' demeanor and nonverbal characteristics observed during voir dire. The plaintiff-appellant did not demonstrate the removal of African-American jurors satisfied the requirements of Batson and, thus, the trial court's rejection of the Batson challenge was not clearly erroneous. Following the trial court's grant of a motion in limine in favor of defendants-appellees, plaintiff-appellant's proffer of evidence at trial addressed only one issue raised in the motion and, accordingly, only that one issue was preserved for review on appeal. Further, the trial court did not abuse its discretion when it excluded the introduction of irrelevant evidence. And where the introduction of evidence about bed bugs was not unfairly prejudicial, the trial court did not abuse its discretion when it permitted the introduction of the evidence.