State v. Robertson

Citations

• 2026 Ohio 1147

Syllabus

The trial court committed plain error in requiring appellant to appear in visible shackles in front of the jury without adequate justification. The jury's view of appellant's shackles was neither brief nor inadvertent, and it occurred in the courtroom, during trial, and just prior to appellant's testimony to assert his affirmative defense of duress. Based on these unique facts, we find this case to be the exceptional circumstance that requires correction of a manifest miscarriage of justice. Accordingly, we reverse appellant's convictions for aggravated robbery, improperly discharging a firearm at or into a habitation, felonious assault, aggravated murder, and felony murder, but we affirm appellant's conviction of murder under Count 7 as the duress defense was not applied to that charge at trial. Judgment affirmed in part and reversed in part.