State v. Bailey

Citations

• 2026 Ohio 481

Syllabus

Appellant was convicted of assault based on punching the victim at a party. The trial court did not abuse its discretion in allowing the State to present an 11-second video of the assault as it was properly authenticated, was not precluded by the best evidence rule, was relevant, and was not unduly prejudicial. Even assuming for the sake of argument that the trial court should have permitted appellant to present evidence of specific prior interactions between the appellant and the victim as proof of the appellant's state of mind for purposes of a self-defense claim, the trial court did not commit reversible error. The evidence demonstrated that appellant was the initial aggressor when the assault occurred. Judgment affirmed.