State v. Branam, 2020 Ohio 3101

On Jan. 1, 2019, Willadean Branam was charged with obstructing official business, spitting in public, marijuana possession, improper signaling when leaving curb, and a license-plate violation.
Branam served a discovery demand; the state produced most materials but delayed providing police body-worn-camera (BWC) and cruiser mobile-video-recorder (MVR) footage, promising to produce when received.
Defense filed a motion to extend suppression-deadline and later a motion to compel, arguing MVR footage was needed to evaluate a suppression motion.
The trial court ordered production within ten days; by the May hearing the state had provided BWC but not MVR footage and said it was not in the prosecutor’s possession despite requests.
Defense moved to dismiss; the trial court, noting the undisclosed video might be exculpatory, dismissed all charges as a sanction. The state appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal was an appropriate sanction for the state’s failure to produce MVR evidence	Trial court abused discretion by dismissing without considering whether the failure was willful, whether knowledge of the material would aid defense, and whether less severe sanctions would suffice	Nonproduction of potentially exculpatory video prejudiced Branam; dismissal was warranted	Reversed: court abused its discretion by not applying the required discovery-sanction factors and not imposing the least-severe effective sanction; remanded for proper consideration

State v. Darmond, 986 N.E.2d 971 (Ohio 2013) (sets factors for discovery-sanction analysis)
State v. Parson, 453 N.E.2d 689 (Ohio 1983) (articulates willfulness, benefit to defense, and prejudice factors)
Lakewood v. Papadelis, 511 N.E.2d 1138 (Ohio 1987) (requires least-severe sanction consistent with discovery purpose)