S. Euclid v. Freeman

Citations

• 2026 Ohio 2406

Syllabus

Sufficiency of the evidence; manifest weight of the evidence; failure to stop after accident; improper passing; plain error; hearsay; Evid.R. 803(6); lay witness; expert witness; Evid.R. 701; Evid.R. 702; discovery violation; record on appeal. The evidence presented at trial was sufficient to support appellant's convictions for failure to stop after an accident and improper passing. Appellant's convictions for failure to stop after an accident and improper passing were not against the manifest weight of the evidence. The trial court erred in allowing the City to introduce hearsay evidence in the form of a repair estimate without first having the author of that estimate testify. However, the appellant did not object to the introduction of the repair estimate on hearsay grounds and therefore waived all but plain error and failed to demonstrate that the outcome of the trial would have been different had the impermissible hearsay not been introduced. The trial court did not err in allowing a law enforcement officer from providing lay witness opinion testimony that was based on his own observations and conclusions. The record on appeal was insufficient to determine whether appellant was not provided with alleged photographs and images within the discovery deadline.