Shaker Hts. v. Patterson

2026 Ohio 745
CourtOhio Court of Appeals
DecidedMarch 5, 2026
Docket115432
StatusPublished

This text of 2026 Ohio 745 (Shaker Hts. v. Patterson) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shaker Hts. v. Patterson, 2026 Ohio 745 (Ohio Ct. App. 2026).

Opinion

[Cite as Shaker Hts. v. Patterson, 2026-Ohio-745.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

CITY OF SHAKER HEIGHTS, :

Plaintiff-Appellee, : No. 115432 v. :

LARRY REGINALD PATTERSON, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: March 5, 2026

Criminal Appeal from the Shaker Heights Municipal Court Case No. 24TRD02535

Appearances:

C. Randolph Keller, City of Shaker Heights Chief Prosecutor, for appellee.

Larry Reginald Patterson, pro se.

EILEEN A. GALLAGHER, J.:

Larry Reginald Patterson (“Patterson”), acting pro se, filed this appeal

after the Shaker Heights Municipal Court found him guilty of two traffic violations.

For the following reasons, we affirm the trial court’s judgment. On May 2, 2024, Patterson was issued a traffic citation in Shaker

Heights for failure to follow traffic signal indications, specifically a red light, in

violation of Shaker Heights Codified Ordinance (“SHCO”) 1113.03 and operating a

motor vehicle without a valid driver’s license in violation of SHCO 1135.01(a).

Patterson failed to appear at two scheduled arraignments and the court issued a

warrant for his arrest on June 27, 2024. On March 26, 2025, Patterson pled not

guilty to the traffic violations.

Patterson filed a motion to dismiss this case on May 6, 2025. In his

motion, Patterson argued that the case against him should be dismissed for the

following three reasons, which are taken verbatim from his court filing:

Suppression of video evidence, which was only disclosed after public records pressure and constitutes a Brady violation;

Ongoing delays and denials in response to my lawful public records and discovery requests;

Indicators of undisclosed financial instruments (bonds or securities) possibly issued against my legal estate or case number, now the subject of federal inquiry through filings with the U.S. Treasury, IRS Whistleblower Office, and U.S. GAO.

The court held a hearing on July 3, 2025, after which it denied

Patterson’s motion to dismiss. The court held a trial on the same date and found

Patterson guilty of both traffic violations.

Patterson appeals and raises two assignments of error for our review.

I. The trial court violated Appellant’s due-process rights by denying full discovery, including requested financial records and audio visual evidence, in violation of Crim.R. 16 and the Fourteenth Amendment. Without access to this material evidence, Appellant was unable to challenge the officer’s testimony or verify procedural integrity, resulting in actual prejudice.

II. The trial court exceeded its jurisdiction and rendered judgment without a complete evidentiary record, depriving Appellant of a fair and lawful proceeding.

The Ohio Supreme Court has “repeatedly declared that ‘pro se

litigants . . . must follow the same procedures as litigants represented by counsel.’”

State ex rel. Neil v. French, 2018-Ohio-2692, ¶ 10, quoting State ex rel. Gessner v.

Vore, 2009-Ohio-4150, ¶ 5. “Pro se litigants are presumed to have knowledge of the

law and legal procedures and are held to the same standard as litigants who are

represented by counsel.” Saeed v. Greater Cleveland Regional Transit Auth., 2017-

Ohio-935, ¶ 7 (8th Dist.).

In Patterson’s appellate brief, he argues that he “submitted multiple

public-records and discovery requests under Crim.R. 16 . . . seeking complete

financial documentation related to fines and bond activity.” Specifically, Patterson

indicated that he requested “(1) financial documentation evidencing bond handling

and (2) audiovisual recordings of the May 6 pretrial proceeding and adjacent

hallway.”

These alleged discovery requests are not part of the record, and we

are unable to verify the content of the requests. Furthermore, our review of the

record shows that Patterson did not file a motion to compel or any other document

that would shed light on his alleged discovery requests.1 In other words, nothing in

1 In Shaker Heights’ appellate brief, it states that on “March 25, 2025, . . . Patterson

filed a Motion for Discovery with the Shaker Heights Municipal Court . . . .” There is no the record indicates that the trial court was aware of, let alone ruled on, an alleged

discovery dispute.

To support his argument under the first assignment of error,

Patterson cites State v. Darmond, 2013-Ohio-966, for the legal proposition that

“[w]here non-disclosure [of discovery] prejudices the accused, reversal is

warranted.”2 Our review of Darmond shows that it is inapplicable to this case. In

Darmond, the Ohio Supreme Court held that a trial’s court’s inquiry into an

allegation of a discovery rule violation “applies equally to discovery violations

committed by the state and to discovery violations committed by a criminal

defendant.” Id. at ¶ 42. Here, nothing in the record shows that the municipal court

inquired into a discovery dispute because nothing in the record shows that the trial

court was aware of a discovery dispute.

Crim.R. 16 governs discovery in criminal cases. Crim.R. 16(L)(1)

states, “If at any time during the course of the proceedings it is brought to the

attention of the court that a party has failed to comply with this rule or with an order

issued pursuant to this rule, the court may order such party to permit the discovery

. . . .” Additionally, Crim.R. 12(C)(4) states, in part, as follows: “The following must

be raised before trial: Requests for discovery under Crim.R. 16.”

such motion in the record of this case, there is no docket entry showing any activity on March 25, 2025, and there is no docket entry of any date showing that Patterson filed a discovery motion with the court.

2 Patterson also cites “City of Fairview Park v. O’Neill, 8th Dist. No. 96491, 2011-

Ohio-6579.” No such case exists in Ohio. The docket indicates that a hearing on Patterson’s motion to dismiss,

which appears to allege arguments similar, if not identical, to the arguments

Patterson raises on appeal, was held on July 3, 2025. Additionally, the docket

indicates that a trial was held the same day. However, the record does not contain

a transcript of any court proceedings in this case. The appellant has the duty to file

the transcript or such parts of the transcript that are necessary for evaluating the

trial court’s decision . . . . Failure to file the transcript prevents an appellate court

from reviewing an appellant’s assigned errors . . . . Thus, absent a transcript or

alternative record under App.R. 9(C) or (D), we must presume regularity in the

proceedings below. Lakewood v. Collins, 2015-Ohio-4389, ¶ 9 (8th Dist.).

In Patterson’s appellate brief, he argues that “[n]o transcript or

recording was supplied” to him. As the above-cited law shows, however, it is

Patterson, as the appellant, who is required to provide this court with a transcript of

the trial court proceedings. See App.R. 9(B)(1) (stating that “it is the obligation of

the appellant to ensure that the proceedings the appellant considers necessary for

inclusion in the record, however those proceedings were recorded, are transcribed

. . . .”); App.R. 9(B)(3) (“The appellant shall order the transcript in writing and shall

file a copy of the transcript order with the clerk of the trial court.”). The prosecutors

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Related

State v. Darmond
2013 Ohio 966 (Ohio Supreme Court, 2013)
State ex rel. Gessner v. Vore
2009 Ohio 4150 (Ohio Supreme Court, 2009)
State ex rel. Neil v. French (Slip Opinion)
2018 Ohio 2692 (Ohio Supreme Court, 2018)
State v. Smith
2020 Ohio 1026 (Ohio Court of Appeals, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 745, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shaker-hts-v-patterson-ohioctapp-2026.