State v. Quinn

Citations

• 2022 Ohio 2038

Syllabus

Joinder of indictments Crim.R. 8(A) Crim.R. 14 plain error failure to comply is probative of guilt Sixth Amendment speedy trial rights Evid.R. 404(B) other acts testimony Evid.R. 801(D)(2)(e) admissions by co-conspirator. Joinder of indictments was proper where the state showed that two or more acts are connected together and defendant failed to show prejudice resulting from joinder. Delay in bringing defendant to trial resulted from Covid-19 pandemic continuances and defense requested continuances, which did not unduly prejudice the defendant. Therefore, his constitutional speedy trial rights were not violated. An isolated remark by a detective about defendant's violent history, which was elicited by defense counsel on cross-examination, did not violated Evid.R. 404(B). Codefendant's statement that he was also a victim of a robbery, but he did not know the identity of the offender, was admissible under Evid.R. 801(D)(2)(e) as a statement by a co-conspirator, because it was made in an effort to conceal the crime.