State v. Johnson

Citations

• 2026 Ohio 757

Syllabus

In allowing the child victims to testify outside of appellant's presence without making any of the factual findings regarding necessity required under the child victim testimony statute, the trial court violated appellant's right to confrontation. The trial court's error was not harmless because without the children's testimony, insufficient evidence supported appellant's convictions as to the children for aggravated menacing and domestic violence (threats). Insufficient evidence supported appellant's conviction of aggravated menacing in relation to his ex-wife, so the trial court erred in overruling his motion for acquittal. Judgment reversed in part, vacated in part, and remanded for a new trial on the charges pertaining to the child victims.