State v. Hatfield

Citations

• 2022 Ohio 148

Syllabus

Appellant was convicted of murder as a proximate result of felonious assault, failure to comply with an order or signal of a police officer, three counts of tampering with evidence, and having weapons while under disability. His convictions for murder and failure to comply were based on sufficient evidence and were not against the manifest weight of the evidence. The trial court did not abuse its discretion in admitting as evidence (1) a recorded phone conversation between appellant and his wife that occurred while appellant was involved in a high-speed car chase with the police, (2) recorded phone calls made by appellant from jail, and (3) lay testimony from the State's forensic digital examiner regarding the contents of cell phones. The trial court did not commit reversible error in its jury instructions on complicity and causation. The trial court did not err in failing to merge tampering with evidence (handgun) and having weapons while under disability as allied offenses of similar import. The trial court's imposition of consecutive sentences was not clearly and convincingly unsupported by the record. Judgment affirmed.