State v. Williams

Citations

• 2024 Ohio 6026

Syllabus

Hearsay; Evid.R. 801(C); Evid.R. 802; exclusions to the hearsay rule; Evid.R. 803; extrinsic evidence; impeachment; Evid.R 103(A); ineffective assistance of counsel; other-acts evidence; Evid.R. 404(B); right to be present during trial; manifest weight of the evidence. Defendant's convictions were affirmed for the following reasons: (1) the trial court did not err when it excluded extrinsic evidence of the victim's purported statement because the statement was hearsay and no exception applied; (2) defense counsel was not ineffective for failing to impeach the victim with her prior recorded statement, and even if defense counsel was ineffective, defense counsel's deficient performance did not prejudice the defendant; (3) the trial court did not err when it permitted the victim to testify to prior abuse by the defendant because it was relevant to establish the victim's fear of the defendant; (4) the trial court did not violate the defendant's right to be present on the morning of the second day of trial due to the defendant's voluntary relinquishment of his right to be present, and (5) the defendant's convictions were not against the manifest weight of the evidence.