State v. Smith

Citations

• 2018 Ohio 4691

Syllabus

The trial court did not err in overruling Appellant's motions for a new trial. Contrary to Appellant's claim otherwise, the State's failure to disclose an audio-recorded conversation between the victim and the investigating detective did not violate the rule announced in Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), because the information on the undisclosed audio recording was cumulative to information already known by the defense prior to trial and/or did not constitute favorable and material evidence that would have affected the outcome of trial. Judgment affirmed.