State v. Elliott

Citations

• 251 N.E.3d 319
• 2024 Ohio 3376

Syllabus

Because the trial court did not abuse its discretion in finding no strong probability that the newly discovered evidence would change the outcome, the trial court did not err in denying defendant's motion for a new trial. The trial court did not err in: (1) excluding from evidence the co-defendant's polygraph results, (2) excluding from evidence the statements the co-defendant made during the pre-test interviews, and (3) refusing to allow the polygraph examiner to testify. Also, the trial court did not violate defendant's confrontation right when it prevented his counsel from cross-examining the co-defendant using the polygraph evidence. No violation of due process occurred when: (1) the prosecutor commented on the victim's disabilities and social challenges during the opening statement, or (2) the trial court admitted testimony of the victim's mother regarding the same topics. The trial court did not err in admitting other-acts evidence under Evid.R. 404(B). Defendant was not deprived of effective assistance of counsel. Defendant's convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. Considering the totality of the circumstances, defendant's complaints regarding his court-appointed counsel did not trigger the trial court's duty to conduct further inquiry into those complaints.