In re C.T.
991 N.E.2d 1171
Ohio Ct. App.2013Background
- This case arises from a delinquency adjudication for raping an acquaintance, with prior acts evidence contested.
- The trial court admitted evidence of C.T.'s prior delinquency for gross sexual imposition as part of the case.
- On remand from the Ohio Supreme Court, this court applies Williams II three-step test to determine admissibility of other acts evidence.
- Williams II refines Evid.R. 404(B) and RC 2945.59 balancing relevancy, proper purpose, and unfair prejudice.
- The court held the prior delinquency evidence was inadmissible, prejudicial, and reversed the adjudication and remanded for a new hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether C.T.'s prior delinquency evidence was admissible under Williams II. | C.T. argues prior acts show MO or intent. | State argues MO and lack of mistake are shown. | Admissible? No; evidence inadmissible under Williams II. |
Key Cases Cited
- State v. Williams, 134 Ohio St.3d 521 (2012) (clarified three-step Williams II framework for 404(B) admissibility)
- Williams I, 195 Ohio App.3d 807 (2011) (initial limits on 'scheme, plan, or system' admissibility under Curry)
- State v. Curry, 43 Ohio St.2d 66 (1975) (two admissibility scenarios for other acts evidence: background or identity)