State v. Gardner

Citations

• 2026 Ohio 2009

Syllabus

VIOLATING PROTECTION ORDER — CRIM.R. 16 — MANIFEST WEIGHT — VENUE: The trial court abused its discretion in issuing two Crim.R. 16 sanctions without considering the necessary factors on the record, but the error was harmless as the State proffered other evidence to establish necessary elements of the offense. Defendant's conviction for violating a protection order was not contrary to the manifest weight of the evidence where the witnesses testified that the victim received messages from the defendant after the defendant received the protection order. The State proffered evidence to establish that the crime occurred in Hamilton County, Ohio, and the trial court's finding that this was the appropriate venue was not contrary to the manifest weight of the evidence.