State v. Savors, 2010 Ohio 6084

Defendant Randy Savors, a Tier III sex offender, was released on parole in 2007 and required to report address changes to the Sheriff.
He initially reported an address at 7383 Depot Street in May–June 2008 but moved on June 22, 2008 without notifying the Sheriff.
Granger and Sgt. Bradley discovered the discrepancy and Bradley filed a felony charge for failure to notify on July 3, 2008; arrest followed on July 7, 2008.
During detention, Bradley updated Savors's Tier III registration, and Savors disclosed a new address, admitting he knew he should have notified the Sheriff.
A grand jury indicted Savors for failure to notify under R.C. 2950.05(A); Savors moved to suppress statements from the registration interview.
The trial court admitted the statements, Savors was convicted after a jury trial, and the court sentenced him to seven years in prison plus five years of parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Indictment defect and on-day amendment to include mens rea	State contends amendment corrects a fillable statutory gap	Savors argues indictment must reflect all elements; amendment violated fairness	Without merit; indictment proper and amendment beneficial to State
Admission of statements from registration interview	State asserts statements were voluntary and admissible	Savors claims custodial interrogation without Miranda warnings	Harmless error; evidence sufficient for guilt beyond a reasonable doubt
Prosecutorial misconduct/closing arguments	Prosecutor comments allowed within broad closing argument	Comments were prejudicial and denied fair trial	Without merit; comments did not deprive defendant of fair trial

State v. Horner, 126 Ohio St.3d 466 (Ohio 2010) (indictment not defective for lack of mental-state element when statute lacks one; Horner controls on mens rea in R.C. 2950.05(A))
State v. Blanton, 184 Ohio St.3d 611 (Ohio 2009) (strict liability offense; failure to register is strict liability; harmless error analysis)