State v. Hoskins

Citations

• 2019 Ohio 4842

Syllabus

CRIMINAL-DOMESTIC VIOLENCE-HEARSAY-EXCITED UTTERANCE-MANIFEST WEIGHT-SUFFICIENCY - The trial court did not abuse its discretion in allowing the victim's statement to be admitted into evidence under the excited-utterance exception to the general rule prohibiting the admission of hearsay where the statement satisfied the four-part test for determining the admissibility of statements as excited utterances. Appellant's conviction for domestic violence was not against the manifest weight of the evidence and was supported by sufficient evidence despite the victim's refusal to cooperate in testifying at trial where the State introduced substantial other evidence upon which the trial court, as the trier of fact, could reasonably conclude that all of the elements of the offense had been proven beyond a reasonable doubt.