State v. Stratton

Citations

• 2025 Ohio 1621

Syllabus

Per Mayle, J., Given his stepson's role as lead detective, Judge Ickes's participation in defendant's case violated defendant's due-process rights because of the constitutionally intolerable probability of actual bias. Consistent with State v. Elkins, 2024-Ohio-5351 (6th Dist.), this constituted error requiring reversal. Child sexual abuse material (\CSAM\) played for the jury was sufficient evidence from which the jury could find \sexual satisfaction.\