Background
Ta’Naejah Guyton was charged in a thirteen-count indictment involving two murders and assaults. In August 2025, she entered a plea agreement, pleading guilty to involuntary manslaughter. At her October 2025 sentencing, the trial court met with attorneys in chambers and viewed a surveillance video of the incident outside the presence of Guyton and her codefendants. The court explained the video was sensitive in nature and requested it be viewed outside the courtroom. Guyton’s attorneys were present during the viewing and did not object to her absence. After viewing the video, no party objected to the procedure. The court sentenced Guyton to three years in prison.
Guyton appealed, claiming her constitutional right to be present at all critical stages of trial was violated when the trial court viewed the surveillance video without her presence.
The Court’s Holding
The Ohio Court of Appeals affirmed the conviction, holding that Guyton failed to demonstrate she was prejudiced by the trial court viewing the surveillance video without her presence. The court noted that while a defendant has a constitutional right to be present at every stage of criminal proceedings, this right is not absolute. Prejudicial error exists only where a fair and just hearing is thwarted by the defendant’s absence.
Because Guyton failed to object to the video viewing, the court reviewed for plain error. Under this standard, the party claiming error must demonstrate that the outcome would have been different absent the error. Here, Guyton’s attorneys were present during the video viewing and had previously seen the video themselves, yet raised no objection. Guyton offered only speculation that she might have received a different sentence (community control instead of prison) had she been present, which the court found insufficient to establish prejudice.
Key Takeaways
- A defendant’s right to be present at trial is not absolute and must be evaluated based on whether a fair hearing would be thwarted by absence.
- When defense counsel is present and fails to object to a defendant’s exclusion, a higher plain-error standard applies requiring demonstration of actual prejudice.
- Speculation about hypothetical different outcomes is insufficient to establish prejudice; concrete evidence must show the proceeding’s result would have been different.
- Trial courts may view evidence outside the defendant’s presence in limited circumstances, particularly at sentencing, without constitutional violation.
Why It Matters
This decision clarifies the scope of a defendant’s constitutional right to be present at sentencing and other trial proceedings. While the right exists, courts need not exclude evidence or delay proceedings when defense counsel is present and does not object, and when the defendant cannot demonstrate actual prejudice from the absence. This gives trial judges flexibility to manage sensitive evidence while maintaining due process.
The holding impacts criminal procedure by establishing that the presence of competent counsel who actively participates in proceedings—and does not object to a defendant’s absence—substantially limits claims that exclusion violated constitutional rights. Defendants must show more than speculation about different outcomes to overcome this burden on appeal.