State v. Blair

Citations

• 2024 Ohio 1061

Syllabus

Felonious assault improperly discharging a firearm endangering children criminal damaging having a weapon while under disability motion for mistrial discovery violation sanction discretion Crim.R. 16 fair trial new trial Crim.R. 33 due process Crim.R. 29 acquittal sufficiency admission of evidence Evid.R. 901 Evid.R. 602 harmless error Crim.R. 52(A). Affirmed appellant's convictions for felonious assault and related counts. The trial court did not abuse its discretion in denying appellant's motions for a mistrial and imposing a less severe sanction for a discovery violation under Crim.R. 16 where appellant was not prevented from receiving a fair trial, nor did the court err in denying appellant's request to set aside the verdict and for a new trial. The trial court did not err in denying appellant's Crim.R. 29 motion for acquittal when sufficient evidence was presented to prove the essential elements of the crimes beyond a reasonable doubt. Appellant's convictions were not against the manifest weight of the evidence. The trial court did not abuse its discretion in the admission of video evidence under the silent witness theory pursuant to Evid.R. 901, in permitting the lead detective to testify to the contents of the video pursuant to Evid.R. 602, or in the admission of several exhibits and any error in this regard was harmless at best.