State v. Sanders

Citations

• 2020 Ohio 5081

Syllabus

Involuntary manslaughter felonious assault having weapons while under disability Evid.R. 612 Evid.R. 803(5) present recollection refreshed abuse of discretion reliability Crim.R. 16 discovery violation Fifth Amendment privilege against self-incrimination standing Evid.R. 801 sufficiency of the evidence manifest weight of the evidence. The trial court did not abuse its discretion in allowing the testimony of a witness following the state's refreshing of her recollection pursuant to Evid.R. 612. The trial court did not abuse its discretion in allowing a witness to testify despite a late disclosure of the witness by the state. The appellant lacks standing to challenge the trial court's decisions regarding a witness's Fifth Amendment privilege against self-incrimination, and the trial court did not abuse its discretion by allowing a witness's former testimony into evidence following a determination that the witness was unavailable. The appellant's convictions were not against the manifest weight of the evidence and were supported by sufficient evidence.