State v. Long, 2011 Ohio 4293

Keith A. Long pled no contest to trafficking in cocaine (fifth degree), trafficking (fourth degree), possession of cocaine (second degree), and possession of criminal tools (fifth degree); aggregate prison term four years with two mandatory years.
Brown County? No—the case is in Greene County, Ohio; discovery disputes arose before trial with Crim.R. 16 and Brady v. Maryland considerations.
State requested discovery including witness lists, records, and potential confidential informant information; Long sought duplicative audio/video copies and informant identity.
Trial court granted some discovery; ordered reciprocal discovery; permitted Long to view tapes at prosecutor’s office rather than providing copies; set informant identity disclosure two weeks before trial.
Long moved to compel further discovery and suppression; a hearing found the State had complied with substantial discovery but could limit copies to protect informant safety.
Long entered a no-contest plea before trial on the suppression/discovery issues; Court of Appeals affirmed the trial court’s discovery handling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State’s failure to provide copies of tapes violated Crim.R. 16	Long argues due process and Brady rights were violated by lack of copies.	Long contends the State’s failure to provide copies impeded defense preparation and cross-examination.	No due process violation; viewing rights satisfied; discovery limits did not deny rights
Whether failure to provide informant information violated confrontation rights	Disclosure was necessary to assess informant credibility and search-warrant affidavit reliability.	Informant data needed for suppression hearing and trial; rights to confront were undermined.	Informant identity to be disclosed; trial court’s approach balanced safety and confrontation; not reversible
Whether failure to disclose informant details affected suppression hearing on probable cause	Missing informant information could have affected the warrant’s credibility.	Informant details would aid suppression; absence prejudices defense.	Probable-cause inquiry confined to affidavit; missing tapes not material; no prejudice established
Whether the trial court abused its discretion in handling discovery order and its modifications	The court failed to enforce discovery and should have compelled copies.	The court properly balanced safety concerns with the defendant’s rights and ordered access instead of copies.	No abuse or plain error; court adequately safeguarded rights and informant safety

State v. Mabry, 2007-Ohio-1895 (Ohio Ct. App. 2007) (Crim.R. 16 mandatory but subject to protective orders; balance rights)
State v. Wickline, 50 Ohio St.3d 114 (1990) (Brady and discovery interaction; disclosure rules satisfied)
State v. Wade, 2007-Ohio-6611 (Ohio Ct. App. 2007) (Brady material and discovery interplay clarified)
State v. McKoy, 2010-Ohio-522 (Ohio Ct. App. 2010) (Crim.R. 16(B)(1)(e) witness protection certification requirements)
State v. Cundiff, 2011-Ohio-3414 (Ohio Ct. App. 2011) (Pretrial discovery limits and information relevance)
State v. Carr, 2009-Ohio-1942 (Ohio Ct. App. 2009) (Crim.R. 16 scope and witness-related disclosures)