State v. Craig

Summary

The Ohio Seventh District Court of Appeals affirmed Alicia Craig’s convictions for two counts of aggravated arson and her consecutive prison sentence. The court held that surveillance video and separately extracted audio recordings were properly authenticated duplicates admissible under Ohio’s best evidence rules. The court also rejected Craig’s plain-error challenge to the fire marshal’s expert testimony, concluding that witness credibility was for the jury and that the record supported the expert’s incendiary-fire opinion.

Holdings

1. DVD copies of surveillance video and separately extracted audio files are admissible to the same extent as the original recordings when properly authenticated, and the trial court did not abuse its discretion in admitting the recordings here.
2. The trial court did not commit plain error by allowing the fire marshal's expert testimony to remain before the jury because credibility and the weight of the expert's opinion were matters for the jury, and the record provided substantial support for the opinion and the convictions.

Questions Presented

1. Whether the trial court erred under Ohio's best evidence and authentication rules by admitting DVD copies of surveillance video and separately extracted audio rather than the original DVR files.
2. Whether the trial court committed plain error by failing sua sponte to strike the fire marshal's expert testimony on the ground that the testimony was not credible.

Disposition

affirmed