State v. Thompson

Citations

• 2025 Ohio 4359

Syllabus

DRUG OFFENSES — WEAPONS — JURISDICTION — CONTEMPT — RIGHT TO BE PRESENT AT TRIAL — DUE PROCESS — CONFRONTATION — COUNSEL WAIVER — OTHER-ACTS EVIDENCE — AUTHENTICATION — FIREARM OPERABILITY — COMPETENCY — SUFFICIENCY — MANIFEST WEIGHT — CONSECUTIVE SENTENCES — CUMULATIVE ERROR: Where the defendant did not challenge the sufficiency of the indictment in the trial court, he waived that issue on appeal; the trial court had subject-matter and personal jurisdiction over defendant, and the judgment of conviction was not void. Where the defendant did not appeal the entry finding him in contempt and imposing a sentence, this court lacked jurisdiction to consider the assignment of error challenging the contempt finding. Defendant waived his right to be present at trial by refusing to attend and participate in his trial. Defendant's being tried despite his refusal to sign the waiver-of-counsel form was harmless error where the trial court engaged in a thorough colloquy that established defendant's waiver of counsel was knowing, intelligent, and voluntary. The trial court did not err in admitting evidence of defendant's prior drug sales where the evidence was necessary and relevant to the background of the offenses and explained the issuance of the search warrant. The trial court did not err in admitting still photos from a recording device where the officer authenticated the photos by testifying to the reliability of the recording device and the accuracy of the photos. The operability of the firearms was proven where the officer testified that a loaded firearm was found on defendant's bed, a firearm with ammunition was found in the headboard of defendant's bed with mail addressed to him, and the firearms, test-fire packs, and ammunition were presented to the jury. Defendant waived the competency hearing by stipulating to the contents of the report finding him competent. The evidence was sufficient to prove defendant constructively possessed the firearms found on his bed and in