State v. Lacey, 2012 Ohio 1697

Lacey was convicted of felonious assault with a firearm specification and sentenced to six years' total incarceration in 2010.
In 2011, Lacey filed a post-conviction relief petition alleging Brady violation and ineffective assistance of counsel, attaching a Liberty Township police incident report.
The State moved for summary judgment, arguing no Brady duty to disclose and that the report was a public record not under the State's control.
The trial court granted summary judgment, denying post-conviction relief without an evidentiary hearing, and citing no further cross-examination on Robbins's criminal history as a trial strategy.
On appeal, Lacey challenged the Brady claim and the effectiveness of counsel; the Seventh District affirmed, holding no Brady violation and no ineffective assistance.
The court concluded the evidence was public-record material not suppressible, and defense counsel's conduct did not prejudice the outcome; thus the judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady violation	Lacey asserts the Liberty Township report impeachment evidence was suppressed.	State contends report was public record and not within its duty to disclose; not material.	No Brady violation; not material.
Ineffective assistance	Lacey argues counsel failed to investigate and discover the report, causing prejudice.	State argues no showing of deficient investigation or prejudice; record lacks proof of outcome change.	No ineffective assistance; no prejudice.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (duty to disclose favorable evidence in criminal cases)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (duty to learn favorable evidence held by others)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective-assistance standard)
State v. Calhoun, 86 Ohio St.3d 279 (Ohio 1999) (post-conviction relief standard and procedures)
State v. Steffen, 70 Ohio St.3d 399 (Ohio 1994) (limits and procedure for post-conviction relief)