State v. Smith

Citations

• 2024 Ohio 5745
• 179 Ohio St. 3d 4

Syllabus

Criminal law—Confrontation Clause of the Sixth Amendment to the United States Constitution—Absent witness's statements to police officer captured on officer's body-camera video were testimonial because officer was not responding to an ongoing emergency when those statements were made, and admission of those statements at trial violated defendant's right to confrontation—Absent witness's statements to EMTs captured on the same body-camera video were nontestimonial because those statements were made for the purpose of receiving medical care, and admission of those statements at trial did not violate the Confrontation Clause—Court of appeals' judgment reversed and cause remanded.