State v. Johnson

Citations

• 2019 Ohio 3877

Syllabus

AUTOS/CRIMINAL – CONSTITUTIONAL LAW/CRIMINAL – SEARCH AND SEIZURE – CRIM.R. 16(K) – EXPERT WITNESS – OPINION TESTIMONY – DRUGS – EVIDENCE – CUMULATIVE ERROR: The trial court did not err in overruling defendant's motion to suppress where the police officer had reasonable suspicion to detain the defendant during a traffic stop to await the arrival of the drug-sniffing dog. Defendant failed to establish that the state did not provide an expert report as required by Crim.R. 16(K) because the defendant did not place the purported expert report into the record. The trial court did not abuse its discretion in qualifying the witness as an expert because the witness had specialized knowledge, skill, experience, and training in fingerprint analysis. The trial court did not abuse its discretion in allowing the police officers to offer lay opinion testimony based upon their perceptions through their experience and training. Defendant's convictions for possession and trafficking of cocaine were supported by sufficient evidence and were not against the weight of the evidence where the evidence showed that defendant was driving a car with cocaine in a bag under his seat and his fingerprint was found on the bag the jury was free to disregard his testimony that he had no knowledge of the drugs in the car. The doctrine of cumulative error is inapplicable where there are not multiple instances of harmless error.