State v. Heyder, 2014 Ohio 1066

Defendant Jacob Heyder was indicted in Franklin County on one count of aggravated robbery, two counts of robbery, and one count of kidnapping for a grocery-store robbery where a knife was involved.
Before trial, Heyder moved to exclude or limit testimony about a knife found in a bathroom after his arrest, requesting identification before admission.
The victim identified Heyder as the robber, but later stated the presented knife was not the knife used in the robbery.
A buck knife found at the time of arrest was identified by DNA as linked to Heyder and later admitted at trial despite objections.
The appellate court held the knife evidence was irrelevant after the victim testified it was not the robbery knife and was prejudicial, warranting reversal and remand.
Judgment reversed and case remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the knife evidence abuse of discretion?	Heyder contends knife testimony was irrelevant and prejudicial.	State argues knife evidence explained why the knife was shown to the victim.	Yes, abuse of discretion; reversal and remand.

Old Chief v. United States, 517 U.S. 172 (1997) (admissibility of prior-conviction evidence; limits of stipulations to avoid prejudice)
State v. Cunningham, 2006-Ohio-6373 (2006) (appellate review of evidentiary rulings; abuse of discretion standard)
Walker v. United States, 490 F.2d 683 (8th Cir. 1974) (irrelevance of post-event evidence to underlying robbery conviction)
Lascola v. State, 61 Ohio App.3d 228 (1988) (prejudicial error admitting irrelevant testimony)
Zamorski v. State, 141 Ohio App.3d 521 (2000) (prejudice from admission of irrelevant evidence)
Beaver(s) v. State, 2012-Ohio-3654 (2012) (abuse of discretion; balancing probative value against prejudice)