State v. Lenard, 2023 Ohio 4529

Richard Marcus Lenard was convicted in 2016 of kidnapping and felonious assault stemming from two physical altercations with his then-romantic partner.
Lenard appealed his conviction, raising concerns about juror No. 5, whom he alleged was biased because of their shared high school history and later negative interactions.
Multiple motions for post-conviction relief and new trial were filed by Lenard, all focusing on alleged juror bias.
Initial challenges based on juror No. 5 were rejected by both the trial court and the appellate court, often on grounds of res judicata and lack of newly discovered evidence.
In his latest motion, Lenard presented new affidavits and exhibits attempting to show he was "unavoidably prevented" from producing evidence of juror bias earlier.
The trial court denied both the motion for leave to file a new-trial motion and a request for a hearing, leading to this appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was new evidence of juror bias sufficient for new trial?	State argued res judicata barred this and evidence was not truly new.	Lenard argued affidavits and exhibits constituted newly discovered evidence.	No; evidence and assertions known/utilizable at trial; barred.
Was Lenard unavoidably prevented from acquiring evidence?	State said effort could have been made sooner with reasonable diligence.	Lenard cited COVID-19, lack of counsel, and late witness contact.	No; evidence could have been obtained with diligence.
Should the trial court have held a hearing on the motion?	Not required unless evidence likely changes result.	Lenard requested a hearing to present the new affidavits/exhibits.	No; no strong probability of different result shown.
Abuse of discretion by trial court in denying motion?	No abuse; followed proper procedure and law.	Lenard argued the court acted unreasonably or arbitrarily.	No abuse of discretion found.

Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse of discretion standard outlined)
State v. McNeal, 169 Ohio St.3d 47 (standard for leave to file new-trial motion discussed)