State v. Harmon

Citations

• 2020 Ohio 590

Syllabus

Trial court did not err by failing to sua sponte grant mistrial because brief references to appellant's criminal record were immediately objected to and corrected by curative instructions to jury. Trial counsel did not perform deficiently by failing to request more specific curative instructions or move for mistrial because counsel could have concluded as a matter of strategy that this would only call more attention to appellant's criminal record. Evidence was sufficient to sustain kidnapping conviction where victim testified appellant put his body against door and held victim's arm, preventing him from leaving apartment. Verdicts were not against the manifest weight of the evidence where there was competing evidence as to whether appellant acted in self-defense jury was in the best position to judge credibility of victim and appellant regarding their different accounts of altercation.