State v. Eytcheson

Citations

• 2018 Ohio 2036

Syllabus

Appellant was not entitled to a trial by jury for failure to reinstate a license and for a seatbelt violation. The trial court did not err in overruling Appellant's motion to dismiss, since the right to operate a motor vehicle upon the highways is not unrestricted but is subject to reasonable regulation. Officer Colon did not violate R.C. 4513.263(D) in initiating Appellant's traffic stop, since the stop was based upon an improper turn and not the seatbelt violation. Officer Colon was not required to advise Appellant of his Miranda rights in the course of the stop. The trial court had discretion to limit the duration and scope of Appellant's closing argument. The trial court did not abuse its discretion in excluding a \statement\ or \document\ from evidence Appellant did not make a proffer of the document, but R.C. 2319.02 requires Appellant to submit an affidavit, and Appellant testified that his injury that arguably prevents him from wearing a seat belt occurred in 2012. The State was not required to prove that Appellant acted knowingly or willfully strict liability attaches to Appellant's offenses. The corpus delicti rules does not apply to Appellant's offenses. The trial court did not lack subject matter or personal jurisdiction. The trial court, as the fact-finder in a bench trial, was authorized to question a witness and did not assume the role of the prosecutor. Judgment affirmed.