State v. Smith

Citations

• 2023 Ohio 1613

Syllabus

Sufficient Evidence Confrontation Clause Forensic Interview 2907.05(C)(2)(a) Corroborating Evidence Reagan Tokes Act. Subtle or psychological forms of coercion are sufficient to demonstrate the element of force in a child rape case where the defendant is a parent or stands in loco parentis to the victim. R.C. 2907.05(C) has been revised to remove the language that required a mandatory prison sentence for a gross sexual imposition conviction that was corroborated by evidence other than the testimony of the victim. This language in former R.C. 2907.05(C) was held unconstitutional by the Ohio Supreme Court.