The Eighth District affirmed convictions for domestic violence and aggravated menacing against EMS workers, holding that the defendant’s verbal death threats to first responders constituted separately punishable offenses from the underlying domestic assault.
The Eighth District reversed the trial court’s dismissal of a rape and kidnapping indictment for preindictment delay, holding that the defendant failed to establish actual prejudice from the 16-year gap between the offense and indictment despite the deaths of two potential witnesses.
The Eighth District reversed a jail-time credit calculation where the trial court awarded credit for days the defendant had already received credit for in a separate, unrelated case, and remanded for factual findings supporting the recalculated credit.
The Eighth District reversed the juvenile court’s denial of mandatory bindover, holding that a juvenile’s own recorded confession admitting he ‘put a gun on’ a victim established probable cause for the firearm display element without requiring victim testimony.
The Eighth District affirmed individual maximum sentences for a jewelry store burglary but remanded for resentencing because the trial court failed to make the disproportionality finding required for consecutive sentences under R.C. 2929.14(C)(4).
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.