State v. Woods

Citations

• 235 N.E.3d 1133
• 2024 Ohio 467

Syllabus

Joinder Crim.R. 8(A) photographs authentication Evid.R. 901(A) motion to suppress voir dire challenge for cause impeachment expert testimony personal knowledge Daubert Evid.R. 702 Evid.R. 703 ballistics evidence sufficiency manifest weight aggravated murder murder felonious assault criminal damaging carrying a concealed weapon ineffective assistance of counsel age as a sentencing factor. Trial court acted within its discretion in joining two cases arising from two separate incidents where the offenses were committed at different locations on different dates and were, therefore, simple and direct. Photographs from crime scene were properly authenticated by an officer who supervised the investigation. Motion to suppress was properly denied where there was no evidence that the search warrant affidavit contained untruthful statements. Denial of motion to excuse juror for cause due to anti-gun sentiments was not an abuse of discretion where the juror stated that she could keep an open mind, would hold the government to its burden of proof, and would listen to the evidence objectively. Trial court acted within its discretion in limiting the scope of cross-examination where defense counsel repeatedly asked objectionable questions and ultimately admitted at side bar that there was no evidence the witness had been reprimanded for dishonesty. Ballistics expert was qualified to testify regarding ballistics testing even though he did not perform the testing himself because he reviewed the examiner's work and had personal knowledge of the testing. Trial court properly admitted ballistic evidence indicating that shell casings found at multiple crime scenes were discharged from the same gun where the methodology used for the ballistics testing had been accepted by multiple courts as meeting the standards outlined in Daubert for admission of scientific evidence. There was sufficient evidence to support defendant's felonious assault and criminal damaging convictions where surveillan