State v. Crawford

Citations

• 2022 Ohio 2673

Syllabus

Sixth Amendment Confrontation Clause remote testimony video testimony COVID-19 Evid.R. 901 authentication abuse of discretion Crim.R. 29 sufficiency of the evidence manifest weight of the evidence ineffective assistance of counsel plain error prosecutorial misconduct closing arguments motion for mistrial Reagan Tokes. The trial court's decision to permit a witness who tested positive for COVID-19 to testify remotely via Zoom did not violate appellant's confrontation rights where there was a legitimate public policy reason for doing so and the three requirements of confrontation were not hindered. Text messages were properly authenticated when numerous witnesses with knowledge of the messages testified that the evidence was authentic. Appellant's convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. Various isolated comments do not amount to plain error, and defense counsel's decision not to object to the comments did not constitute ineffective assistance of counsel. Comments made during the state's closing argument were not improper and did not constitute plain error. The trial court's denial of appellant's motion for mistrial following a juror outburst was not an abuse of discretion. Appellant's indefinite sentence pursuant to the Reagan Tokes Law does not violate his constitutional rights.