State v. Black, 109 N.E.3d 716

On August 14, 2015, Nicholas Duecaster drove Keith Black; an altercation later occurred during which Duecaster was shot and hospitalized for about a month. Black was arrested after a six-day evasion.
Duecaster testified Black produced a gun, demanded money, shot him, then jumped/fell from the car; Black testified the shooting occurred during a struggle after Duecaster pulled a gun on him.
The State presented physical evidence including damage at the Ravenwood scene consistent with Duecaster’s account and Black’s DNA on a magazine clip; the firearm was not recovered.
The State sought admission of a Facebook photo from Black’s account showing Black with a bandaged hand the same day; Black objected to authentication and prejudicial effect.
A jury convicted Black of felonious assault (with a firearm specification) and having a weapon while under disability; trial court imposed consecutive sentences totaling 14 years.
The appellate court affirmed the convictions, held the Facebook photo was authenticated by Black’s own testimony, rejected the manifest-weight challenge, but remanded for a nunc pro tunc entry to incorporate consecutive-sentencing findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Facebook photo was properly authenticated	Photo was authenticated by Black’s testimony identifying the picture’s subject, date, and location	Photo was unauthenticated hearsay and unduly prejudicial; State had prior possession via victim’s sister	Admitted: Evid.R. 901(A)/(B)(1) satisfied because Black himself identified the photo on cross-examination; not unduly prejudicial
Whether convictions were against the manifest weight of the evidence	Evidence (victim testimony, scene damage, DNA on magazine, flight) supports that Black knowingly shot Duecaster	Black’s self-defense account created reasonable doubt — shooting was accidental during struggle	Affirmed: Jury credibility determinations supported; verdict not against manifest weight
Whether the sentencing entry complied with R.C. 2929.14(C)(4) / Bonnell	Court orally made required consecutive-sentence findings at hearing	Written judgment failed to incorporate those findings verbatim	Remand for nunc pro tunc entry: oral findings sufficient but must be reflected in written entry

State v. McGuire, 80 Ohio St.3d 390 (1997) (trial court has broad discretion to admit evidence)
State v. Tingler, 31 Ohio St.2d 100 (1972) (gruesome or inflammatory evidence may be excluded)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight standard and framework)
State v. Hill, 75 Ohio St.3d 195 (1996) (credibility is primarily for the trier of fact)
State v. DeHass, 10 Ohio St.2d 230 (1967) (appellate review deference to jury credibility determinations)
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (1984) (appellate presumption that trial-court findings are correct)
State v. Bonnell, 140 Ohio St.3d 209 (2014) (consecutive-sentence findings must be made at hearing and incorporated into the judgment entry)