State v. Smith

Citations

• 2025 Ohio 3131

Syllabus

MOTION TO SUPPRESS — MIRANDA — EVID.R. 404(B) — MURDER — WEIGHT OF THE EVIDENCE: The trial court did not err in denying defendant's motion to suppress under Miranda where the evidence showed that defendant was not subjected to a custodial interrogation at the time defendant voluntarily told detectives that he was not at the scene of the shooting, but instead at a Bengals tailgate and then out of town. The trial court did not err under Evid.R. 404(B) in admitting defendant's ex-girlfriend's testimony that defendant threatened to set her on fire the night before defendant allegedly shot and killed the victim outside the ex-girlfriend's apartment: The State offered defendant's threatening statement in the context of the ex-girlfriend's broader testimony regarding the events leading up to the shooting, and the evidence was relevant to explain defendant's identity as the shooter and his intent when the shooting occurred. Defendant's murder conviction was not against the manifest weight of the evidence where defendant's ex-girlfriend testified that she had called the victim to change the locks on the front door of her apartment to keep defendant out when defendant arrived unannounced and a fight ensued between defendant and the victim, the victim was shot, defendant left the scene, and police could not locate any firearm at the scene of the shooting.