State v. Hardin, 953 N.E.2d 847

Hardin was convicted in a bench trial of felony murder and endangering children in Pike County, Ohio.
The autopsy of Junior Hardin Jr. was performed by a deputy coroner; the supervising coroner, Gorniak, offered opinions relying on the autopsy report.
Dr. Sohn performed the autopsy; his report was introduced at trial along with accompanying toxicology materials.
Gorniak testified that Junior died of a subdural hematoma due to nonaccidental head trauma, concluding homicide by blunt force trauma or shaking.
Dr. Scribano testified that the injuries could not have been caused by sofa-cushion manipulation and required significant force, basing his conclusions on materials beyond the autopsy report.
Hardin challenged the admission of the autopsy report and the doctors’ opinions as violative of the Sixth Amendment confrontation rights and evidentiary rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confrontation clause and coroner's report	Hardin contends coroner's report is testimonial and violates confrontation.	State argues coroner's report is a nontestimonial public record under existing law.	Report admissible as nontestimonial public record; confrontation rights not violated.
Admission of physicians' opinions under Evid.R. 703	Gorniak's and Scribano's opinions rely on underlying records not properly admitted.	Experts’ opinions were properly based on admissible records and were helpful to the independent conclusions.	Admission upheld; any error harmless.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (established framework for testimonial evidence under Sixth Amendment)
Davis v. Washington, 547 U.S. 813 (U.S. 2006) (distinguishes testimonial vs nontestimonial statements in emergencies)
Melendez-Diaz v. Massachusetts, 557 U.S. 304 (U.S. 2009) (certificates prepared for trial are testimonial)
State v. Craig, 110 Ohio St.3d 306 (2006-Ohio-4571) (coroner’s report admissible as nontestimonial business record)
State v. Fouty, 110 Ohio App.3d 130 (1996) (court addressed limitations on basis for expert conclusions)
State Univ. Bd. of Trustees v. Smith, 132 Ohio App.3d 211 (2009) (tribunal limits on evidentiary abuse; standard for reviewing evidentiary rulings)