Toledo v. Blade, 2023 Ohio 658

Blade and A.B. were in a relationship and share a child; A.B. obtained a civil protection order after incidents of aggressive behavior by Blade.
On January 21, 2022, A.B. received phone calls; Blade allegedly told her, “you’ll end up in jail…and you’ll end up dead,” prompting her to call police.
Officers observed A.B.’s phone repeatedly receive calls showing Blade’s picture; a criminal complaint (domestic violence and menacing) and a TPO followed.
On January 24, 2022, police located Blade in his vehicle, served an arrest warrant, and charged him additionally with resisting arrest after he was removed from the car.
Bench trials were held; the court found Blade guilty of domestic violence and resisting arrest and imposed jail time, probation, and no-contact/protective-order conditions.
On appeal Blade raised two issues: (1) Brady violation for alleged nondisclosure of body-worn camera footage, and (2) manifest-weight challenge to the domestic-violence conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Alleged Brady violation for nondisclosure of body‑cam footage	State: No suppression—defense did not request footage, footage was discoverable at trial, and no evidence footage existed	Blade: Body‑cam footage was favorable/exculpatory and would prove his innocence and impeach officer testimony	Court: No Brady violation—defense never requested footage, possible footage was revealed at trial (so Brady inapplicable), and existence of footage was speculative
Manifest‑weight challenge to domestic‑violence conviction (R.C. 2919.25(C))	State: Threats, context (recent destructive incident, proximity, immediate police call, witness observations) supported that victim reasonably feared imminent physical harm	Blade: Victim admitted not fearing immediate danger; he lacked access to a weapon and had no weapons convictions, so fear was unreasonable	Court: Conviction affirmed; evidence and credibility findings support that a reasonable person in victim’s position could fear imminent harm; not an exceptional case warranting reversal

Brady v. Maryland, 373 U.S. 83 (establishes prosecutor’s duty to disclose favorable material evidence)
Strickler v. Greene, 527 U.S. 263 (defines components of a Brady/Giglio claim)
Giglio v. United States, 405 U.S. 150 (testimonial-impeachment evidence and nondisclosure principles)
United States v. Agurs, 427 U.S. 97 (Brady rule and discovery timing clarified)
State v. Wickline, 50 Ohio St.3d 114 (Ohio follows Agurs—Brady applies to evidence discovered after trial)
State v. Thompkins, 78 Ohio St.3d 380 (standard for manifest-weight review)
State v. Johnston, 39 Ohio St.3d 48 (following Brady)
State v. Antill, 176 Ohio St. 61 (trial court’s role as factfinder and credibility determiner)
State v. Fisher, 197 Ohio App.3d 591 (victim’s belief and intent inference for domestic‑violence prosecutions)