State v. Baldwin, 2023 Ohio 3795

Victim (age 10) awoke around 4:00 a.m. and identified Brandon Baldwin as the person who digitally raped her while she slept on the living-room floor; she told a friend the next day and the mother later.
Baldwin lived with the family, was often away for work, and told investigators he was in the house that night looking for the TV remote and remembered seeing the victim asleep.
At a bench trial the court found Baldwin guilty of rape of a child under 13 and sentenced him to life with parole eligibility after 25 years; several gross-sexual-imposition counts were acquitted.
Baldwin sought to admit (1) evidence that a sibling had allegedly committed past sexual misconduct as an alternate suspect, and (2) extrinsic evidence impeaching the mother about when her relationship with her fiancé began; both lines were excluded by the trial court.
Baldwin moved for a mistrial based on an alleged text/contact by the mother to another witness and asserted the mother perjured herself about the timing of her relationship; the trial court denied a mistrial.
On appeal Baldwin argued the exclusions and denial of mistrial denied his right to present a complete defense and to impeach witnesses; the appellate court affirmed.

Issue	State's Argument	Baldwin's Argument	Held
Exclusion of evidence of another suspect (sibling's past misconduct)	Past misconduct by sibling was irrelevant, unduly prejudicial, and not shown to connect to the incident	Evidence was necessary to show an alternate perpetrator and complete defense	Exclusion affirmed; past allegations were speculative and not material to the charged incident
Exclusion of extrinsic impeachment of the mother regarding timing of her relationship	Proffered evidence was not offered to show bias and was improper extrinsic evidence under Evid.R. 608(B)/613 without giving the mother chance to explain	Could use extrinsic evidence under Evid.R. 616(A) to impeach mother and show motive to fabricate	Exclusion affirmed; impeachment evidence inadmissible as extrinsic for character-truthness attack and mother was not afforded chance to explain prior inconsistent statement
Denial of mistrial for alleged witness contact/perjury by the mother	Contact was tangential, unrelated to elements of the crime, and did not deprive Baldwin of a fair trial	Contact/perjury on timing of relationship showed bias and required mistrial	Denial affirmed; alleged misconduct was speculative and not so prejudicial as to make a fair trial impossible

Crane v. Kentucky, 476 U.S. 683 (1986) (due-process right to present a complete defense)
Washington v. Texas, 388 U.S. 14 (1967) (compulsory process and presentation of witnesses)
United States v. Valenzuela-Bernal, 458 U.S. 858 (1982) (defendant must make plausible showing that absent evidence would be material and favorable)
State v. Craig, 110 Ohio St.3d 306 (2006) (need for evidence linking another suspect to current offense to admit prior acts)
State v. Swann, 119 Ohio St.3d 552 (2008) (limits on right to call witnesses and present evidence)
State v. Sage, 31 Ohio St.3d 173 (1987) (admission/exclusion of relevant evidence reviewed for abuse of discretion)
State v. Warmus, 197 Ohio App.3d 383 (2011) (limitations on extrinsic evidence to attack character for truthfulness)
State v. Jones, 35 N.E.3d 934 (2015) (prior-misconduct questioning must be clearly probative of truthfulness)
State v. Garner, 74 Ohio St.3d 49 (1995) (standard for declaring mistrial when fairness is compromised)