State v. Dodridge

Citations

• 2025 Ohio 2856

Syllabus

CRIMINAL-DOMESTIC VIOLENCE - The trial court did not err in declaring the victim to be a hostile witness under Evid.R. 611(C), nor did it err in interrogating the victim in accordance with Evid.R. 614(B); although the victim's prior written statement that was attached to the police was erroneously admitted into evidence as extrinsic evidence of impeachment, the error was harmless beyond a reasonable doubt; plain error did occur as a result of the trial court's failure to provide a limiting instruction, nor was trial counsel ineffective for failing to request a limiting instruction; body cam video that was destroyed was not materially exculpable evidence and the defendant failed to prove that the State acted in bad faith in failing to preserve potentially useful evidence; because the defendant's conviction for disrupting public services was supported by sufficient evidence, the trial court did not err in denying his Crim.R. 29(A) motion for judgment of acquittal; defendant failed to demonstrate that he was deprived of his right to a fair trial as a result of cumulative error.