State v. Lawson

Citations

• 2020 Ohio 3008

Syllabus

Trial court judgments convicting defendant following bench trial affirmed. Data obtained from a GPS device covertly attached to defendant's automobile pursuant to a search warrant was testimonial hearsay prepared for the primary purpose of accusing a targeted individual or for providing evidence in a criminal trial, and was therefore admitted by the trial court in violation of defendant's Sixth Amendment right to confront witnesses against him. Testimony of shooting victim and on-the-record statements by trial judge show that violation of Confrontation Clause was harmless beyond a reasonable doubt, and convictions were not against the manifest weight of the evidence.