State v. Curtiss

Citations

• 2022 Ohio 146

Syllabus

While records of a children's services agency pertaining to abuse are confidential, the trial court abused its discretion by failing to disclose relevant and material records following an in camera inspection. The court also violated appellant's right to confrontation to appellant's prejudice by limiting his right to cross-examine a primary prosecution witness. Other error occurred as well, such as allowing admission of hearsay evidence, but appellant failed to object. When reviewed under a plain error analysis, this error did not create a manifest miscarriage of justice, particularly since the judgment is being reversed due to other prejudicial error. Judgment reversed and remanded.