State v. Covington

Citations

• 2025 Ohio 1720

Syllabus

BRADY VIOLATION – EVID.R. 404(B) – OTHER ACTS EVIDENCE – IDENTITY – RELEVANCE – CUMULATIVE ERROR – MANIFEST WEIGHT: The State did not commit a Brady violation despite twice failing to timely share evidence with defendant, because the late disclosure did not impede defendant from effectively using the evidence at trial. The trial court did not abuse its discretion when it admitted 56 anonymous text messages from more than 40 different phone numbers sent roughly 90 days before the date of the incident identified in the complaint, because the texts constituted other-acts evidence for the permitted purpose of identifying defendant as the sender of the texts \on or about\ the date of the incident set forth in the complaint. Where there were no errors that deprived defendant of a fair trial, defendant failed to establish cumulative error. The defendant's conviction for violating a protection order was not contrary to the manifest weight of the evidence where the record demonstrates that the text messages received by the victim were sent by defendant as the messages referenced aspects of the parties' former romantic relationship, defendant's nicknames for the victim, personal information about the victim that defendant would have known and explicit photographs of the victim allegedly taken by the defendant.