State v. Leach

Citations

• 2024 Ohio 3145

Syllabus

Defendant appeals convictions for two counts of rape of a child under the age of ten. Appellant's confrontation clause rights were not violated when the child's grandmother recounted the child's out-of-court statements. Appellant was not prejudiced by the late disclosure of a voicemail that was cumulative evidence. The trial court did not commit plain error by not providing a limiting instruction following a sustained hearsay objection. The trial court did not abuse its discretion in disallowing evidence that the child had viewed a sexually explicit television program. The prosecutor did not engage in misconduct at sentencing by advising the trial court of evidence that appellant may have previously sexually abused the child.