State v. Lammie
Citations
- 2026 Ohio 1109
Syllabus
Evidence of Prior Convictions for Impeachment Purposes; Evid.R. 609(B); Abuse of Discretion; Limiting Instruction; Merger; R.C. 2941.25; Plain Error. The trial court did not abuse its discretion when it admitted evidence of the defendant-appellant's prior convictions. The prior convictions are within the ten-year time limit and involve crimes of dishonesty and moral turpitude. Defense counsel's decision not to request a limiting instruction regarding the jury's use of the defendant-appellant's prior convictions can be a tactical one. Trial courts should not interfere with the tactical decisions of defense counsel by stepping in and sua sponte giving a limiting instruction. Therefore, the trial court did not commit plain error by failing to sua sponte give a limiting instruction. The defendant-appellant cannot establish the first element of the plain-error test—that an error occurred—because the trial court did not err by sentencing the defendant-appellant on the felonious-assault and domestic-violence convictions.
Judges: Zimmerman
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7 cases in this archive are cited by this case.
- Blakemore v. BlakemoreOhio Supreme Court· 1983-07-06· cited 14,330×
- State v. LongOhio Supreme Court· 1978-02-15· cited 3,848×
- State v. BirosOhio Supreme Court· 1997-05-14· cited 432×
- State v. BaileyOhio Supreme Court· 2022-12-14· cited 155×
- Oberlin v. Akron Gen. Med. Ctr.Ohio Supreme Court· 2001-03-27· cited 90×
- State v. ToppingOhio Court of Appeals· 2012-11-19· cited 23×
- State v. DayOhio Court of Appeals· 2025-12-18· cited 3×
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