State v. Liccardo

Citations

• 2026 Ohio 1864

Syllabus

Manifest weight of evidence; sufficiency of evidence; complicity jury instruction; criminal conviction on nontestifying witness; sentence. Judgment affirmed. The State presented sufficient evidence supporting the murder and felonious-assault convictions under either a principal-offender theory or complicity theory. The weight of the evidence supported the convictions. The trial court did not abuse its discretion by instructing the jury on complicity. The trial court did not abuse its discretion by prohibiting the defense from inquiring of the investigating detective about a nontestifying witness's prior criminal record. The evidentiary rules governing prior convictions relate to testifying witnesses and defendants, not nontestifying witnesses. Pursuant to the Supreme Court of Ohio's decision in State v. Bollar, 2022-Ohio-4370, and this court's decision in State v. Dobson, 2025-Ohio-2148 (8th Dist.), the trial court did not err by sentencing the defendant on the firearm specifications for merged counts.