State v. Ramsey

Citations

• 210 N.E.3d 1088
• 2023 Ohio 807

Syllabus

Amended indictment Crim.R. 7 grand jury evidence disclosure of grand jury transcripts particularized need insufficiency of the evidence Crim.R. 29 motion for judgment of acquittal and manifest weight of the evidence. The trial court's grant of the state's motion to amend the dates of the indictment was in accordance with Crim.R. 7 and did not prejudice the defendant and, therefore, did not constitute an abuse of discretion. Absent the defendant demonstrating a particularized need to review the grand jury transcripts, the trial court's refusal to disclose the transcripts was not an abuse of discretion. Where the evidence was sufficient to support defendant's convictions at the close of the state's case-in-chief and following the defendant's case-in-chief, defendant's insufficiency of the evidence and Crim.R. 29 motions for judgment of acquittal lacked merit. A review of the record demonstrated that the trier of fact did not lose its way and create a manifest miscarriage of justice when it convicted defendant.