State v. Oatneal

Citations

• 2025 Ohio 2357

Syllabus

After an alleged domestic violence incident, appellant-boyfriend called the police, stating there was no emergency but he wanted to file a restraining order; this prompted a police officer's response to girlfriend's location in a nearby parking lot. The police officer's encounter with girlfriend was recorded on his body camera and used at appellant's trial for domestic violence; girlfriend did not testify at trial, and there was no other evidence of her version of events. The admission of body camera footage of girlfriend's interview with the police officer violated appellant's rights under the confrontation clause. There was no ongoing emergency, the statements were testimonial in nature, and they did not qualify as excited utterances. As such, there was insufficient evidence to support appellant's conviction. Judgment vacated.