Mt. Vernon v. Link, 2014 Ohio 4231

Defendant Wayne Link was charged with misdemeanor criminal damaging for allegedly damaging a Mount Vernon Public Library security camera on August 20, 2013; he pled not guilty and demanded a jury trial.
Link requested discovery and later filed a motion to compel, asserting the prosecutor possessed undisclosed exculpatory evidence and noting perceived inconsistencies in a security guard’s statements.
The City produced the library daily security log and an incident report; the prosecutor denied having additional evidence.
At trial the court heard the motion to compel and denied it, then overruled Link’s motion in limine seeking to exclude the library surveillance video and related testimony.
The surveillance video (Exhibit 1) was authenticated and admitted through library security guard Justin Thompson, who testified about the system and copying procedures; Link objected to authentication, relevancy, and inflammatory effect.
A jury convicted Link; the court sentenced him to 90 days jail (with possible suspension if he completed a psychological evaluation). Link appealed, raising (1) denial of his motion to compel discovery and (2) denial of his motion in limine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying Link's motion to compel discovery / whether the prosecutor violated Brady by withholding exculpatory evidence	City: Prosecutor had no additional evidence to disclose; production satisfied discovery	Link: Prosecutor withheld exculpatory evidence/material witness information needed to prepare defense	Court: No Brady violation shown — record contains no affirmative proof of undisclosed favorable evidence; motion denial affirmed
Whether the trial court abused discretion by denying motion in limine to exclude surveillance video (and whether a limiting instruction was required)	City: Video was authenticated and relevant to the issues; admission proper	Link: Video lacked proper authentication, was irrelevant to damages, and was inflammatory; limiting instruction required	Court: No abuse of discretion — security guard properly authenticated video; limiting-instruction argument waived for failing to raise at trial; admission affirmed

Brady v. Maryland, 373 U.S. 83 (suppression of favorable evidence violates due process)
Moore v. Illinois, 408 U.S. 786 (elements required to establish Brady violation)
Mason v. Swartz, 76 Ohio App.3d 43 (motion in limine is within trial court's discretion)
Estate of Johnson v. Randall Smith, Inc., 989 N.E.2d 35 (abuse-of-discretion standard for in limine rulings)