State v. Geddes, 2021 Ohio 4115

In 2012 Geddes was adjudicated a "mentally ill person subject to court order" in Fayette C.P. Case No. CRI20110189, creating a weapons disability under R.C. 2923.13(A)(5).
In January 2020 a parole search of Geddes' home found an operable firearm and other weapons; he was indicted for having weapons while under disability.
At trial the state authenticated the 2012 adjudication; defense sought to admit a 2015 judgment entry terminating Geddes' commitment and to question the clerk about it.
The trial court excluded the 2015 entry as irrelevant, ruling termination of hospitalization did not by itself relieve the statutory weapons disability.
The jury convicted Geddes; the court sentenced him to 30 months' imprisonment. Geddes appealed, arguing exclusion of the 2015 entry denied his due-process/right-to-present-a-defense.
The appellate court affirmed, holding (1) the statutory disability arises from the prior adjudication and is not automatically negated by termination of commitment, (2) relief must proceed under R.C. 2923.14 or another recognized operation of law, and (3) knowledge of the disability is not an element of the offense.

Issue	Geddes' Argument	State's Argument	Held
Whether the 2015 judgment terminating Geddes' commitment was admissible/relevant	The 2015 entry terminated his status and thus relieved the weapons disability "under operation of law or legal process"; excluding it deprived him of a defense	The 2015 entry merely ends hospitalization but does not relieve the statutory weapons disability; the entry is irrelevant to the charge	Exclusion was proper—termination of commitment alone does not relieve the R.C. 2923.13(A)(5) disability; evidence was not relevant
Whether R.C. 2923.13 permits automatic relief when prior status terminates	The statute's phrase "has been found" allows subsequent legal action (like termination) to change status and remove the disability	The statute creates a disability based on the prior adjudication and requires relief via R.C. 2923.14 or another recognized operation of law	The plain text requires relief by operation of law or legal process (e.g., R.C. 2923.14); termination of hospitalization here did not satisfy that requirement
Whether knowledge of the disability is an element of the offense (due-process notice claim)	Geddes contends he lacked notice because he believed the 2015 entry resolved the disability	State cites precedent that knowledge of disability is not required—only knowing possession must be proven	Court affirmed that knowledge of the disability is not an element; no due-process violation shown

Renfro v. Black, 52 Ohio St.3d 27 (Ohio 1990) (trial judge is best positioned to assess relevance of evidence)
State v. Hancock, 108 Ohio St.3d 57 (Ohio 2006) (appellate courts defer to trial court relevance determinations)
State v. Bryant, 160 Ohio St.3d 113 (Ohio 2020) (apply plain meaning when statutory language is clear)
State v. Johnson, 128 Ohio St.3d 107 (Ohio 2010) (R.C. 2923.13 does not require proof of knowledge of the disability)