State v. Branam

Citations

• 2020 Ohio 3101

Syllabus

CRIM.R. 16 – DISCOVERY – SANCTIONS: Where the state failed to provide to defendant video from the police cruiser's mobile video recorder, the trial court abused its discretion by dismissing the charges against defendant, the harshest sanction possible for the state's discovery violation, where the court failed to consider (1) whether the failure to disclose was a willful violation of Crim.R. 16, (2) whether foreknowledge of the undisclosed material would have benefited defendant in the preparation of a defense, and (3) whether defendant was prejudiced.