State v. Bradford

Citations

• 2024 Ohio 2233

Syllabus

ADMISSIBILITY – EVIDENCE – EVID.R. 404(B) – OTHER ACTS – SUFFICIENCY – MANIFEST WEIGHT: Where defendant was convicted of violating a protection order, the trial court erred in violation of Evid.R. 404(B) by admitting evidence of the underlying offense that resulted in the issuance of the protection order because the validity of the protection order was not a material issue in the case because defendant stipulated to the validity and service of the protection order, but the error was harmless because there is no reasonable possibility that this evidence contributed to his conviction given the other evidence presented at trial. [See CONCURRENCE: The erroneous admission of other-acts evidence that defendant threw urine on the victim would not be harmless if defendant's identity were at issue.] Defendant's conviction was supported by sufficient evidence and not against the manifest weight of the evidence where the protection order prohibited defendant from entering the victim's place of employment, the victim was a streetcar operator, a witness testified that defendant was on the streetcar platform as the victim approached, and the factfinder found the witness's testimony to be credible.