State v. Ellis

Citations

• 2025 Ohio 4675

Syllabus

Murder; firearm; postconviction relief; R.C. 2953.23(A)(1); jurisdiction; untimely; Brady violation; exculpatory evidence; material; handgun; ballistic; report; undisclosed; reasonable probability; mere possibility; reasonable diligence; constitutional error; clear and convincing; guilty. Affirmed trial court's denial of appellant's petition for postconviction relief because the trial court did not have subject-matter jurisdiction to consider the untimely petition. Appellant did not demonstrate a Brady violation where he had not shown a reasonable probability of a different outcome or that there was any failure to disclose material exculpatory evidence, and he offered nothing more than a mere possibility that the undisclosed evidence might have helped the defense. He otherwise failed to meet the requirements of R.C. 2953.23(A)(1).