State v. Byrd

Citations

• 2026 Ohio 2317

Syllabus

Foundation; expert testimony; lay witness testimony; Evid.R. 701; Evid.R. 702; strangulation; R.C. 2903.18; abuse of discretion; admission of evidence; treating physician; ineffective assistance of counsel; self-defense; R.C. 2901.05(B)(1). Judgment Affirmed. The State set forth sufficient foundation for a treating physician to answer whether visible signs of injury to the neck are always present when someone is strangled. Further, the trial court did not err in allowing this testimony under Evid.R. 701, lay witness testimony. Based on the video evidence and appellant's own testimony, self-defense was not valid claim; therefore, trial counsel was not ineffective when he did not argue self-defense.