State v. Tomlinson, 2012 Ohio 1441

Tomlinson was convicted on multiple counts in Summit County Court of Common Pleas in a joint trial with codefendant Smith.
Officers surveilled 1373 Gurley Circle based on intelligence of drugs and weapons; a discarded bag of crack cocaine was found in a paddy wagon after Smith's arrest.
A second vehicle exit led officers to observe Tomlinson carrying a large garbage bag; they obtained a warrant to search the Gurley Circle residence.
Search of the residence yielded firearms and crack cocaine; Tomlinson claimed he disposed of items after receiving a call.
Indictment charged multiple counts of possession and trafficking of cocaine, weapons while under disability, and possession of criminal tools, with related forfeiture provisions; Tomlinson moved to suppress evidence and was later convicted on most counts with total sentence of eleven years.
The court denied suppression; Tomlinson appeals raising five assignments of error, which the court addresses and overrules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court abuse its discretion by denying recross-examination?	Tomlinson asserts denial impeded fair cross-examination.	State contends discretion lies with trial court when no new matters arise on redirect.	No abuse of discretion; recross-examination properly limited.
Was a mistrial warranted due to testimony about suppressed evidence?	State's witness testified about evidence suppression; mistrial requested.	State argues no suppression error tainted trial; mistrial not required.	Mistrial denied; no reversible error.
Was the jail telephone recording admitted in plain error for lack of authentication?	Recording admitted without proper authentication under Evid.R. 901(B)(5).	Admission was harmless due to corroborating testimony and defense evidence.	No plain error; admission harmless.
Was it proper to redact the forensic lab reports after stipulation?	Redaction of subject line prejudiced Tomlinson by obscuring ownership.	Redaction permitted to avoid juror confusion; no prejudice shown.	Redaction proper; no reversible error.
Do cumulative errors require reversal?	Numerous errors collectively deprived Tomlinson of a fair trial.	Errors, if any, were not collectively prejudicial; trial fair.	Cumulative error claim overruled.

Faulkner v. State, 56 Ohio St.2d 42 (1978) (recross-examination within trial court discretion)
State v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard for evidentiary rulings)
State v. Barnes, 94 Ohio St.3d 21 (2002) (plain-error review and substantial rights)