State v. Platt

Citations

• 2024 Ohio 1330

Syllabus

Involuntary manslaughter and endangering children - Sufficient evidence supported appellant's involuntary-manslaughter and endangering-children convictions appellant's failure to secure loaded guns in a locked location inaccessible to children and his failure to properly supervise the three weapons-curious children created a substantial risk of serious harm to his two children and their overnight guest appellant's conduct or failure to act caused the death of 11-year-old child as a proximate result of committing endangering children, even though appellant did not actually fire the weapon appellant's conduct or failure to act was a substantial factor in causing the child's death the child's death was a foreseeable risk of appellant's failure to secure loaded guns in a lock location inaccessible to children and failure to properly supervise the three weapons-curious children - Trial court did not plainly err by permitting law enforcement officer to testify about his gun-safety and gun-storage practices officer's testimony helped explain how a reasonable parent might choose to store guns so as to reduce risk that children will be able to access loaded weapons - Trial counsel was not ineffective for failing to raise 31 objections to various testimony - Cumulative error doctrine did not apply - Appellant's sentencing argument meritless based upon State v. Hacker, __ Ohio St.3d __, 2023-Ohio-2535, __ N.E.3d __.