State v. Smiley

Citations

• 2025 Ohio 2674

Syllabus

Ineffective assistance of counsel; preindictment delay; due process; actual prejudice; failure to object; Confrontation Clause; Sixth Amendment; investigation; cross-examination; Smith v. Arizona; testing analyst; testifying analyst; statements; hearsay; testimonial; harmless error; plain error; Evid.R. 803(4); social worker testimony; manifest weight. Affirmed. Appellant's counsel was not ineffective because (1) a motion for preindictment delay would have been futile; (2) the failure to object to hearsay evidence was harmless error; and (3) counsel's cross-examination falls within the realm of trial strategy. Appellant's convictions were not against the manifest weight of the evidence.