State v. Sowders

Citations

• 2022 Ohio 2401

Syllabus

BAIL – R.C. 2937.222 – STANDARD OF REVIEW – CLEAR AND CONVINCING EVIDENCE: The denial of bail under R.C. 2937.222 is immediately appealable. While a trial court must find that the state established the conditions set forth in R.C. 2937.222(B) by clear and convincing evidence before denying an accused bail, an appellate court, when reviewing the trial court's determination, examines the record to determine if the trial court had sufficient evidence before it to satisfy the clear-and-convincing standard. Where the record contained sufficient evidence in support of the trial court's findings of the conditions set forth in R.C. 2937.222(B) to satisfy the clear-and-convincing standard, the trial court did not err in granting the state's motion to hold defendant without bail.