The Eighth District reversed the dismissal of a felony OVI enhancement, holding that the defendant failed to make a prima facie showing that a prior uncounseled conviction was constitutionally infirm where signed written waivers documented a knowing waiver of counsel.
The Fifth District affirmed a felonious assault conviction arising from an attack at a juvenile correctional facility, holding that inconsistent verdicts between co-defendants do not invalidate a guilty verdict and that the evidence supported a finding of serious physical harm.
The Tenth District reversed a community-control sanction imposed on a defendant who vandalized the Brutus Buckeye statue, finding the trial court failed to hold the required violation hearings and denied the defendant his right to allocution.
The Ninth District reversed a contempt finding, holding that community control violations in misdemeanor cases cannot be prosecuted as criminal contempt under R.C. 2929.25 and that the trial court lacked authority after community control expired.
The Ninth District reversed a zoning conviction because the trial court failed to conduct an adequate inquiry before accepting the defendant’s waiver of counsel, holding that the brief colloquy was insufficient given the complexity of the zoning regulatory scheme.
The Ninth District upheld an Alford plea but remanded for resentencing because the trial court failed to make any findings under R.C. 2929.14(C)(4) before imposing consecutive sentences.
The Ninth District affirmed a murder conviction, holding that the defendant forfeited jury instruction challenges by failing to object and that Ohio’s self-defense presumption under R.C. 2901.05(B)(2) was unavailable because the victim had a right to be in the residence.
The Ninth District dismissed the State’s appeal of a trial court’s refusal to compel witness testimony, holding that R.C. 2945.44 requires full transactional immunity and that the State’s offer excluding murder was insufficient to compel testimony over a Fifth Amendment invocation.
The First District affirmed a juvenile delinquency adjudication for felonious assault, holding that FaceTime-based identification combined with social media confirmation was sufficient and that DYS commitment was appropriate for a first-time offender who fired a gun at a victim.
The First District affirmed an OVI conviction, holding that probable cause to arrest does not require completed standardized field sobriety tests when the totality of officer observations supports impairment.