State v. Flannery

Citations

• 2026 Ohio 1076

Syllabus

GRAND JURY — TESTIMONY — CRIM.R. 6(E) — DISCLOSURE: Where defendant had a particularized need to establish whether exculpatory evidence was presented to the grand jury, and where the State stipulated it had not presented any exculpatory evidence to that body, defendant's particularized need was met and the trial court abused its discretion in ordering disclosure of additional testimony from the grand jury transcript.