State v. Williams, 2011 Ohio 4726

Williams was convicted by a jury of violating a protection order, a fifth-degree felony due to a prior such conviction, and sentenced to one year in prison.
The August 29, 2009 incident occurred at Courtney Fails’s residence, where Williams and several others confronted Fails with weapons while Fails and her son’s father trially sought police assistance.
Williams presented an alibi defense; Patterson and Stewart testified on her behalf, while Williams argued the police officers who came to the scene should have testified.
The State introduced BMV records and testimony related to Williams’s prior conviction, her knowledge of the denial of a protection order, and other ancillary matters.
The court admitted some contested evidence (including BMV records) and allowed questions about Williams’s prior conviction and her children, over a defense objection in parts.
On appeal, Williams challenged (1) the denial of the right to call police witnesses and (2) the admissibility of certain records and testimony; the court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to call police witnesses vs. defense strategy	Williams argues due process was violated; police officers should have testified.	Williams’s counsel chose not to call officers; credibility rests on defense witnesses.	First assignment overruled; trial court did not deny due process; counsel’s strategic choice stands.
Admissibility of BMV records and related testimony	State’s BMV records were improperly authenticated and prejudicial.	Either self-authenticating or admissible as public records; any error harmless.	Admission held harmless; BMV records may be self-authenticating or admissible as public records; no reversible error.

Chambers v. Mississippi, 410 U.S. 284 (1973) (due process includes right to present witnesses; fair trial)
Washington v. Texas, 388 U.S. 14 (1967) (right to present witnesses applies to state and federal trials)
Swann, 2008-Ohio-4837 (Ohio Sup. Ct.) (due process and right to present witnesses referenced in context of defense)
State v. Sage, 31 Ohio St.3d 173 (1987) (abuse of discretion standard for evidentiary rulings)
State v. Hancock, 2006-Ohio-160 (Ohio Sup. Ct.) (abuse of discretion framework for trial court evidence decisions)
State v. Reid, 2010-Ohio-1686 (Ohio App. 6th Dist.) (Evid. 609 prior-conviction evidence rules applied)
State v. Lawson, 2010-Ohio-3114 (Ohio App. 6th Dist.) (admission and use of prior conviction evidence; proper curative instructions)
State v. Lee, 191 Ohio App.3d 219 (2010-Ohio-6276) (BMV records; self-authentication debate with Evid.R. 902)