State v. Reed

Citations

• 2026 Ohio 1174

Syllabus

Criminal law—Crim. R. 8(A) and 14—Crim.R. 8(A) permits offenses of same or similar character to be joined in a single indictment—Crim.R. 14 requires severance if a defendant is prejudiced by joinder—Severance is not required if evidence is simple and direct—In applying simple-and-direct test, the inquiry is on whether the evidence of each offense is separate and direct, whether the evidence is uncomplicated, and whether jury is likely to be confused—Trial court did not abuse its discretion in determining that joinder was not prejudicial, because the evidence was simple and direct—Court of appeals' judgment reversed and trial court's judgment and sentence reinstated.