State v. Treece

Citations

• 2025 Ohio 4319

Syllabus

Joinder; Simple and Direct Test; Plain Error. The law generally favors joining multiple criminal offenses together for trial. However, separate trials are to occur if the joinder of the charges would prejudice the defendant. The defendant cannot demonstrate prejudice where the evidence presented at trial satisfies the simple-and-direct test. Under this test, evidence is simple and direct if the jury can readily separate the proof for each offense; the evidence is unlikely to confuse the jurors; the evidence is straightforward; and there is little danger that the jury would improperly consider the evidence of one offense as corroborative of the others.