State v. Smith

[This opinion has been published in Ohio Official Reports at 179 Ohio St.3d 4.] THE STATE OF OHIO, APPELLANT, v. SMITH, APPELLEE. [Cite as State v. Smith,

2024-Ohio-5745.] Criminal law—Confrontation Clause of the Sixth Amendment to the United States Constitution—Absent witness’s statements to police officer captured on officer’s body-camera video were testimonial because officer was not responding to an ongoing emergency when those statements were made, and admission of those statements at trial violated defendant’s right to confrontation—Absent witness’s statements to EMTs captured on the…