State v. Fetter, 2013 Ohio 4640

Defendant Brandon Fetter was indicted for aggravated vehicular homicide and two OVI counts after a February 1, 2012 head‑on collision that killed Michael Ford.
Evidence: Fetter admitted drinking and told officers he was “slightly buzzed”; a blood sample ~3 hours after the crash showed BAC 0.155.
Crash reconstruction testimony placed fault on Fetter for failing to yield while turning left; State’s experts testified alcohol impaired Fetter’s driving.
Defense sought to introduce evidence that the decedent, Ford, was not wearing a seatbelt and argued that this broke the causal link to Ford’s death.
Trial court excluded all evidence of seatbelt nonuse under Ohio Rev. Code §4513.263(F)(1) and instructed the jury to disregard any such evidence; jury convicted on all counts.
On appeal, Fetter argued the exclusion violated his right to present a full defense; the appellate court reviewed statutory interpretation de novo and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence that the decedent was not wearing a seatbelt was admissible in Fetter's criminal prosecution	The State relied on R.C. 4513.263(F)(1) to exclude seatbelt‑use evidence as not admissible in criminal prosecutions other than seatbelt offenses	Fetter argued exclusion prevented him from presenting a complete defense because nonuse of a seatbelt could break causation between his conduct and the victim’s death	Court held R.C. 4513.263(F)(1) is unambiguous and bars such evidence in this criminal action; exclusion affirmed

Washington Cty. Home v. Ohio Dept. of Health, 178 Ohio App.3d 78 (Ohio Ct. App. 2008) (statutory interpretation reviewed de novo when language is plain)
State v. Siferd, 151 Ohio App.3d 103 (3d Dist. 2002) (when statute is unambiguous, courts give words their ordinary meaning)
Proctor v. Kardassilaris, 115 Ohio St.3d 71 (Ohio 2007) (court should read statutory language in context and apply usual meanings)