State v. Richey

Citations

• 170 N.E.3d 933
• 2021 Ohio 1461

Syllabus

To prove retaliation in violation of R.C. 2921.05(A), the State does not have to establish that the defendant communicated a threat of harm directly to the victim. Where the defendant is charged with retaliation in response to issuing unlawful threats, the State must only prove that the defendant was aware that the threats would be communicated to the victim or that the defendant could reasonably have expected the threats to have been communicated to the victim. Other acts evidence may be admitted under Evid.R. 404(B) for the legitimate purposes of establishing motive and identity.