State v. Galluzzo

Citations

• 2019 Ohio 2999

Syllabus

The trial court did not err in denying appellant's demurrer to the trial court's territorial jurisdiction without holding a hearing because demurrers have been abolished in cases involving misdemeanors. In addition, appellant's claim that the trial court erred in failing to require the State to place proof of the trial court's territorial jurisdiction on the record cannot be reviewed on appeal because appellant failed to file a transcript of the proceedings. Therefore, we must presume the regularity of the proceedings, which includes a presumption that the State established at trial that appellant's offenses occurred within the trial court's territorial jurisdiction. Finally, appellant's claim that the trial court lacked personal jurisdiction lacks merit since personal jurisdiction was accomplished through appellant's arrest and subsequent arraignment in open court. Judgment affirmed.