State v. Harris

Citations

• 2020 Ohio 4461

Syllabus

Murder Evid.R. 701 abuse of discretion opinion testimony lay witness sufficient evidence manifest weight. The trial court did not abuse its discretion in permitting the detective to testify regarding the bullet's trajectory where the detective testified as a lay witness to an opinion based on his experience as a police officer, his perception of the evidence, and his personal observations during an investigation, and the detective's testimony was helpful to determine facts in issue. Appellant's convictions were supported by sufficient evidence where the medical examiner concluded the manner of death was homicide and ruled out suicide and accidental death based upon the absence of fouling and presence of stippling, the muzzle-to-target distance, the location of the injuries sustained by the victim, the bullet's trajectory, and the absence of a gun near the body or the crime scene. The convictions were not against the manifest weight of the evidence.