State v. Durbin

Citations

• 2025 Ohio 5724

Syllabus

EVID.R. 404(B) — OTHER-BAD-ACT EVIDENCE — PLAIN ERROR — EVID.R. 801 — EVIDENCE — SUFFICIENCY AND WEIGHT OF THE EVIDENCE — R.C. 2903.11 — FELONIOUS ASSAULT: No plain error resulted from the trial court's admission of evidence about defendant's drug use where the evidence was relevant for the nonpropensity purpose of establishing defendant's motive and where defendant suffered no prejudice from admission of the evidence. Where a statement is an admission of a party opponent and is not hearsay, a separate analysis must be conducted to determine whether the statement is admissible under Evid.R. 404(B). Where defendant checked into a hotel to avoid arrest, the trial court did not abuse its discretion in admitting a video of defendant's subsequent arrest because the video was relevant and admissible as evidence of consciousness of guilt. Defendant's conviction for felonious assault was supported by sufficient evidence and not contrary to the manifest weight of the evidence where the record shows that the victim was dragged and run over by a vehicle driven by defendant and suffered serious physical harm.