State v. Smith

Citations

• 2025 Ohio 5512

Syllabus

Grand Jury; proceedings; transcript; evidence; particularized need; secrecy; disclosure; speculation; cost; burden; Crim.R. 6(E); R.C. 2939.11. The trial court did not abuse its discretion in denying appellant's petition for disclosure of grand-jury proceedings because the appellant failed to demonstrate a particularized need. The appellant's speculation that the transcripts might be useful to impeach witnesses in a separate civil case, and that obtaining the information independently would be burdensome, was insufficient to warrant disclosure.