State v. Tarrance

Citations

• 2024 Ohio 1952

Syllabus

EVIDENCE – PROTECTION ORDER - AUTHENTICATION OF DOCUMENTS – SUFFICIENCY – DOUBLE JEOPARDY: In a prosecution for violating a protection order under R.C. 2919.27, the trial court erred in admitting into evidence a copy of a protection order that was not certified or testified to as correct by a witness who compared the copy with the original order. Because the state did not present a certified copy of the protection order, it failed to prove a prima facie element of the offense, and therefore, the evidence was insufficient to support the conviction. When a conviction is reversed due to insufficient evidence, the double-jeopardy clause bars a retrial.