State v. Zimmerer

Citations

• 2020 Ohio 3921

Syllabus

Appellant's conviction for voyeurism was supported by sufficient evidence where the victim testified that she looked over her shoulder and saw appellant's arm outstretched behind her body holding his phone, which was in camera mode, displaying on its screen the edge of her dress, her legs, and the back of her thigh, which would have been covered by her dress while appellant was at the victim's home to service her air conditioner. The trial court did not err by admitting evidence that appellant had photographed a woman's backside while she was climbing her basement steps while appellant was on a service call at the woman's house as that evidence was admissible to show an absence of mistake or accident where appellant claimed it was an accident that his phone's forward-facing camera was turned on and pointed up the victim's skirt.