State v. Patterson

Citations

• 2017 Ohio 1444

Syllabus

Preindictment delay, joinder and severance, insufficient evidence, and allied offenses. The trial court did not err in denying appellant's motion to dismiss for preindictment delay because the appellant could not establish a viable, tangible connection between what T.T.'s mother could testify to and his defense. The trial court did not err when it denied the appellant's motion to sever because he could not establish that he was prejudiced by the state's decision to prosecute all of the cases together. There was sufficient evidence to convict the appellant of rape because after viewing the evidence in a light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a reasonable doubt. The trial court did not err when it did not merge the appellant's rape and kidnapping convictions because the offenses were dissimilar in import or significance and caused separate, identifiable harm, were committed separately, and were committed with separate animus or motivation.