State v. Morris, 132 Ohio St. 3d 337

State appeals Morris's two rape-of-a-minor convictions; admissibility of other-acts under Evid.R.404(B) is central.
Trial admitted several other-acts proofs: mother's testimony about relationship and defendant's abusive behavior; towels ejaculation mention; sister's sexual proposition incident.
Limiting instruction given to jury describing purposes for other-acts evidence.
Appellate court held certain 404(B) proofs improper and reversed/remanded; de novo review used.
Supreme Court granted reconsideration to resolve standard of review for 404(B) evidentiary decisions.
Court holds trial-court admissibility decisions under 404(B) are reviewed for abuse of discretion; remands for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What standard governs appellate review of 404(B) decisions?	Morris argues abuse-of-discretion standard should apply.	State contends de novo review is appropriate to legal question.	Abuse-of-discretion standard applies; remand for proceedings.

State v. Lowe, 69 Ohio St.3d 527 (1994) (standard for Evid.R. 404(B) admissibility)
State v. Broom, 40 Ohio St.3d 277 (1988) (non-exhaustive list of 404(B) purposes)
State v. Curry, 43 Ohio St.2d 66 (1975) (other-acts may be part of background/related to crime)
State v. Diar, 120 Ohio St.3d 460 (2008) (abuse-of-discretion review for evidentiary rulings)
State v. Sage, 31 Ohio St.3d 173 (1987) (admission rests in sound discretion of trial court)
Med. Mut. of Ohio v. Schlotterer, 122 Ohio St.3d 181 (2009) (distinguishes factual/legal questions for review standards)
Castlebrook, Ltd. v. Dayton Properties Ltd. Partnership, 78 Ohio App.3d 340 (1992) (questions of law vs. evidentiary rulings in review)
Kokitka v. Ford Motor Co., 73 Ohio St.3d 89 (1995) (mixed law/fact review considerations)