State v. Dunn

Citations

• 2024 Ohio 600

Syllabus

When the complaining witness failed to appear for trial, the trial court found that the forfeiture by wrongdoing exception to the hearsay rule applied to the use of her prior statements at trial, because appellant had sent a threatening letter to her from jail and had had repeated contact with her by phone notwithstanding a no-contact order. Appellant waived any argument that the trial court erred in finding forfeiture by wrongdoing by subsequently entering a guilty plea to intimidation. Ineffective assistance of counsel is not demonstrated in defense counsel's alleged failure to advise appellant to plead no contest, and the record reflects that the trial court substantially complied with Crim.R. 11 in accepting appellant's guilty plea. Judgment affirmed.