State v. Williamson

Citations

• 2017 Ohio 7098

Syllabus

The trial court did not err in allowing a redacted jail telephone call to be admitted into evidence. First, Appellant waived any error by failing to accept the State's offer to make another copy of the jail call. In addition, no error occurred in admission, as the State met the threshold requirement for authentication under Evid.R. 901. Even if error had occurred, there was no basis for reversing the judgment under a plain error analysis. The judgment was also not against the manifest weight of the evidence and was supported by sufficient evidence. Finally, the trial court did not err in overruling Appellant's motion to suppress evidence. Police officers had a reasonable, articulable suspicion for detaining Appellant, and no evidence was obtained during the detention. Concerning a warrantless search of an automobile Appellant had been driving, Appellant disclaimed any interest in the automobile or its contents. As a result, Appellant had no legitimate expectation of privacy in the automobile or its contents, and had no cognizable Fourth Amendment challenge to the officers' search. Affirmed.