State v. Pulley, 2015 Ohio 3635

Erika Pulley was charged with one count of child endangering after being found in a small motel room at the Mason Inn with her seven-month-old son and a man; the room was filled with marijuana smoke and the man sold crack cocaine during their presence.
The only witness at trial was a Warren County Sheriff's Office detective who conducted surveillance of the Mason Inn on October 14, 2011.
On direct examination the detective testified about his employment, surveillance, and that the Mason Inn was in Deerfield Township, but he was not asked to identify Pulley or to state that the Mason Inn was in Warren County.
Cross-examination focused solely on whether Pulley’s son had been tested for illegal substances.
On redirect, over Pulley’s objection, the trial court permitted the detective to identify Pulley and to testify that the Mason Inn was in Warren County.
The municipal court found Pulley guilty after a one-day bench trial and sentenced her to 90 days in jail; Pulley appealed alleging redirect exceeded the scope of cross-examination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by allowing identification and venue testimony on redirect examination	State: Redirect was within the court’s discretion and related to matters establishable from direct testimony	Pulley: Redirect exceeded scope of cross-examination and introduced new, prejudicial evidence (identification and venue)	Court: No abuse of discretion; identification and venue on redirect were permissible and not unfairly surprising

State v. Wilson, 30 Ohio St.2d 199 (trial court has broad discretion to control the scope of redirect examination and interrogation of witnesses)