State v. Huffman, 2016 Ohio 8093

Huffman was convicted in Wayne County Municipal Court of vehicular manslaughter under R.C. 2903.06(A)(4) for allegedly failing to yield to Gray's right of way, causing his death.
Huffman and Gray collided after Huffman stopped at a stop sign on SR 539 and attempted a left turn onto SR 604; Bushes allegedly obstructed Huffman’s view to the west.
The State moved to exclude lay-witness opinions on intersection danger and the motorcycle’s quietness; the trial court granted the motions.
Trial proceeded with lay-witness testimony proffered pretrial but not presented in chief; the State did not object, and the issue was not preserved for appeal.
The jury convicted Huffman; she received probation, license suspension, and community service.
On appeal Huffman argues the trial court abused its discretion by excluding relevant lay-witness testimony and that the conviction reflects a weight-of-the-evidence error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the exclusion of lay-witness testimony violated Huffman’s defense	Huffman	State	No reversible error; issue not preserved for review
Whether the verdict was against the manifest weight of the evidence on causation	Huffman	State	Conviction not against the weight of the evidence

State v. Hipkins, 69 Ohio St.2d 80 (Ohio 1982) (proffer requirement for excluded testimony clarified)
State v. Gilmore, 28 Ohio St.3d 190 (Ohio 1986) (modifies Hipkins re: apparent record of excluded evidence)
State v. Grubb, 28 Ohio St.3d 199 (Ohio 1986) (appellate review of motion in limine requires timely objection)
State v. Otten, 33 Ohio App.3d 339 (Ohio App.3d 1986) (weight-of-the-evidence standard; exceptional cases for reversal)