State v. Galloway

Citations

• 2017 Ohio 5841

Syllabus

Trial court did not err in denying appellant's Crim.R. 33(B) request for leave to file a motion for new trial. A 12-year delay between discovering evidence and seeking leave to file is unreasonable. Appellant was not entitled to an evidentiary hearing because his request was untimely and he did not make a prima facie showing that he was unavoidably prevented from discovering the new evidence. Judgment affirmed.