City of Campbell v. Rosario, 101 N.E.3d 681

On Jan. 19, 2016 Sgt. Charles “Butch” stopped Hernan Rosario, Jr., and cited him for driving 39 mph in a 25 mph zone; Sgt. Butch said he used a radar/laser device to measure speed.
Rosario requested discovery on Feb. 11, 2016 seeking officer notes, diagrams, recordings, and other materials; the prosecutor produced only the front and back of the traffic citation.
Rosario moved to dismiss for failure to provide discovery and because the citation did not indicate how speed was measured; the trial court denied the motion.
At bench trial (Apr. 8, 2016) the state called Sgt. Butch; Rosario testified in his own defense. The trial court found Rosario guilty and fined him $125.
On appeal the Seventh District held the state complied with Crim.R. 16 as it produced the only evidence it intended to use, and that failure to note the measurement method on the citation does not require dismissal.
However, the court reversed the conviction because the state failed to introduce evidence establishing the scientific reliability of the speed-measuring device (and the trial court did not take judicial notice of reliability).

Issue	Plaintiff's Argument (Rosario)	Defendant's Argument (State)	Held
Did the state violate Crim.R. 16 by failing to produce discovery?	City failed to provide officer notes/other materials requested, hindering defense.	State produced the citation and had no other discoverable materials to produce.	No violation — state complied by producing the only evidence it intended to use.
Does a citation that omits how speed was measured require dismissal?	Omission prevents meaningful defense; due process violation.	Ticket apprises defendant of the offense and ordinance; method need not appear on face of ticket.	No — omission is not fatal; citation satisfied requirements.
Was the evidence sufficient to support conviction given officer testimony about device testing?	Device readings were unreliable or improperly documented; insufficiency of evidence.	Officer testified device performed automatic and manual tests and he was qualified to operate it.	Partially: device setup/testing evidence was sufficient for functioning, but insufficient overall because scientific reliability of the device was not established.
Must the state prove scientific reliability of a speed-measuring device?	Rosario argued no reliable proof was offered; conviction unsupported.	State did not present expert testimony or seek judicial notice but relied on officer testimony about testing.	Yes — state must prove scientific reliability by expert testimony or judicial notice; failure to do so requires reversal.

North Olmsted v. Greiner, 9 Ohio App.3d 158 (8th Dist.) (traffic ticket need only apprise defendant of nature of charge and statute/ordinance)
Cleveland v. Austin, 55 Ohio App.2d 215 (8th Dist.) (same principle regarding sufficiency of citation)
State v. Thompkins, 78 Ohio St.3d 380 (standard for reviewing sufficiency of evidence)
State v. Goff, 82 Ohio St.3d 123 (standard: view evidence in light most favorable to prosecution)
East Cleveland v. Ferell, 168 Ohio St. 298 (proof device was functioning properly may rest on technician setup and functioning tests)
State v. Barnes, 94 Ohio St.3d 21 (plain error standard outline)
State v. Robinson, 162 Ohio St. 486 (definition of sufficiency as legal standard)
State v. Pepin-McCaffrey, 186 Ohio App.3d 548 (discussing sufficiency review)