State v. Dodson

Citations

• 2023 Ohio 701

Syllabus

Trial court did not abuse its discretion in denying appellant's motion for leave to file delayed motion for new trial without holding a hearing. Appellant failed to show he was was unavoidably prevented from discovering the allegedly new evidence upon which his motion for new trial would purport to be based. Neither did the trial court err in denying appellant's motion for in camera review of the State's file and sealing for appellate review. Appellant failed to prove a Brady violation that rises to a violation of due process because he made no plausible showing to establish a basis for his claim that the State's file contained material evidence. Judgment affirmed.