State v. Brown

Citations

• 2024 Ohio 749

Syllabus

Criminal law—Robbery—Court of appeals erred in determining that evidence was insufficient to support trial court's conclusion that appellee committed a theft offense and that in doing so, he threatened to inflict physical harm on two different people—R.C. 2911.02(A) (defining robbery as threatening to inflict physical harm on another while committing a theft offense) does not require that theft victim be person who was threatened—A defendant may not assert error on appeal based on late disclosure of evidence alleged to be materially exculpatory that was not disclosed until trial unless defendant raised the issue in trial court by requesting continuance or mistrial or by some other means— Appellee forfeited claim that he was entitled to new trial based on state's purported violation of Brady v. Maryland—Court of appeals' judgment reversed and cause remanded for court of appeals to consider appellee's remaining assignments of error.