State v. Williams

Citations

• 2020 Ohio 1367

Syllabus

AUTOS/CRIMINAL – MOTION FOR A MISTRIAL – AGGRAVATED VEHICULAR HOMICIDE – EVIDENCE – R.C. 4511.19(D)(1)(a): Where a witness's testimony that defendant had previously been incarcerated was an isolated and vague statement, and where the jury heard no other testimony about defendant's prior record and was unaware of what prior offense defendant had committed, the trial court did not abuse its discretion in denying the defendant's motion for a mistrial. Under R.C. 4511.19(D)(1)(a), it was not necessary for the state to establish that tests of defendant's bodily substances were conducted in substantial compliance with Ohio Administrative Code regulations before evidence that drugs and alcohol had been found in defendant's system was admitted in a prosecution for the offenses of aggravated vehicular homicide and driving under the influence of alcohol or drugs, where the evidence was accompanied by expert testimony. Defendant's conviction for aggravated vehicular homicide was not against the manifest weight of the evidence where the defendant admitted to multiple persons that he had been driving the vehicle at the time of the accident, the vehicle involved in the accident was registered to defendant, and defendant's DNA was found on the driver's airbag.