State v. Lautanen

Citations

• 217 N.E.3d 59
• 2023 Ohio 1945

Syllabus

CRIMINAL - Illegal Use of a Minor or Impaired Person in Nudity-Oriented Material or Performance R.C. 2907.323 sufficiency of the evidence manifest weight of the evidence culpable mental state of R.C. 290-7.323 is recklessness transfer of material encompasses sending pictures from one of defendant's electronic devices to another of his or her own devices authentication of cellphone extraction report Evid.R. 901 abuse of discretion Sixth Amendment Confrontation Clause cell phone extraction report was not testimonial in nature because it was a machine-generated report report was not generated by a person's analysis and only human input was plugging the phone into a machine consecutive sentences R.C. 2929.14(C) merger R.C. 2941.25 de novo review one transfer of separate images not subject to merger because each image represents a separate and identifiable harm to the same or different victims.