State v. Slaughter

Citations

• 2026 Ohio 1190

Syllabus

Strangulation; domestic violence; lay opinion testimony; testimony about another case; manifest weight of the evidence. Judgment affirmed. The trial court did not abuse its discretion by allowing the investigating detective to testify as a lay witness regarding domestic violence and strangulation. The detective was a veteran law-enforcement official who had over two decades of experience investigating domestic-violence cases. The detective also had specialized training and education on strangulation. His testimony was based on his training and experience, and it assisted the jury. The trial court did not abuse its discretion by allowing the victim to testify that, in the hours leading up to the within incident, a case against the appellant, in which she was also the named victim, had been dismissed. The testimony about the dismissed case was not offered to show that appellant had a propensity to commit a crime or that he acted in conformity with bad character. Rather, it was offered because it was inextricably intertwined with this case and was necessary to give context to what occurred in this case. The strangulation and domestic-violence convictions were not against the manifest weight of the evidence. The jury was in the best position to make credibility determinations, and there is nothing exceptional about its determinations in this case.