State v. Withers

Citations

• 2026 Ohio 2290

Syllabus

Criminal law-Evid.R. 404(B) does not prohibit evidence of a dog's prior attack-Evid.R. 404(B) applies to a person, not to a dog-Evidence regarding a dog's prior attack was relevant in a prosecution involving R.C. 955.22 and was not unfairly prejudicial-Evidence was sufficient to support appellant's involuntary-manslaughter and R.C. 955.22 convictions when the evidence showed that appellant's dogs escaped the house and killed a person-Trial counsel was not ineffective-Judgment affirmed.