State v. Addicott

2025 Ohio 1785
CourtOhio Court of Appeals
DecidedMay 19, 2025
Docket2024-T-0076
StatusPublished

This text of 2025 Ohio 1785 (State v. Addicott) 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
State v. Addicott, 2025 Ohio 1785 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Addicott, 2025-Ohio-1785.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT TRUMBULL COUNTY

STATE OF OHIO, CASE NO. 2024-T-0076

Plaintiff-Appellee, Criminal Appeal from the - vs - Court of Common Pleas

TRENT ADDICOTT, Trial Court No. 2024 CR 00438 Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: May 19, 2025 Judgment: Affirmed in part, reversed in part, and remanded

Dennis Watkins, Trumbull County Prosecutor, Ryan J. Sanders and Charles L. Morrow, Assistant Prosecutors, Administration Building, Fourth Floor, 160 High Street, N.W., Warren, OH 44481 (For Plaintiff-Appellee).

Michael A. Partlow, P.O. Box 1562, 3435 Kent Road, Stow, OH 44224 (For Defendant- Appellant).

JOHN J. EKLUND, J.

{¶1} Appellant, Trent Addicott, appeals his judgment of conviction from the

Trumbull County Court of Common Pleas. Following a jury trial, Appellant was convicted

on two counts of Pandering Sexual Obscenity Involving a Minor, second-degree felonies

in violation of R.C. 2907.321; four counts of Pandering Sexually Oriented Matter Involving

a Minor, second-degree felonies in violation of R.C. 2907.322; and five counts of Sexual

Conduct with an Animal, second-degree misdemeanors in violation of R.C. 959.21 and

959.99. {¶2} Appellant has raised one assignment of error arguing that the trial court

repeatedly permitted the introduction of hearsay evidence, which violated his rights under

the Confrontation Clauses of the United States and Ohio Constitutions.

{¶3} Having reviewed the record and the applicable caselaw, we find Appellant’s

assignment of error to have some merit. First, admission of the records that were

introduced linking an I.P. address to Appellant was not inadmissible hearsay. They were

properly authenticated records kept in the regular course of business. Next, Appellant’s

arguments that three CyberTipline Reports and related testimony violated his

confrontation rights have some merit. They were not offered for the proof of the matter

asserted as to Counts 1 and 2 and 7 through 11. But they were offered in part to prove

the truth of the matters they asserted related to Counts 3 through 6. The CyberTipline

Reports were not properly admitted as business records, and we cannot determine that

the records were nontestimonial. Nor did any exception to the general rule that hearsay

is not admissible apply to them. Evid.R. 802. So, their admission was error.

{¶4} Therefore, we affirm in part, reverse in part, and remand for further

proceedings consistent with this opinion.

Substantive and Procedural History

{¶5} On June 12, 2024, Appellant was indicted on the following: Counts 1 and

2: Pandering Sexual Obscenity Involving a Minor, second-degree felonies in violation of

R.C. 2907.321(A)(1); Counts 3 through 6: Pandering Sexually Oriented Matter Involving

a Minor, second-degree felonies in violation of R.C. 2907.322(A)(1); and Counts 7

through 11: Sexual Conduct with an Animal, second-degree misdemeanors in violation of

R.C. 959.21 and 959.99. Appellant pled not guilty.

PAGE 2 OF 19

Case No. 2024-T-0076 {¶6} On August 27, 2024, the matter proceeded to jury trial. The following facts

and evidence were adduced at trial:

{¶7} The State called Arabelle Skelly, an analyst with the Cuyahoga County

Prosecutor’s Office working for the Ohio Internet Crimes Against Children Task Force.

Skelly said that she receives “CyberTipline Reports” from the National Center for Missing

and Exploited Children (NCMEC). When Electronic Service Providers (ESPs), such as

Snapchat, Instagram, and Facebook, identify potential Child Sexual Abuse Material

(CSAM) on their site, they report the information to the NCMEC. It creates a CyberTipline

Report and forwards it to an Internet Crimes Against Children Task Force (ICAC) office

where the suspected user is believed to be located. Upon receipt of a Report, Skelly takes

steps to determine who the reported user is. If she determines the possible identity of the

user associated with the reported content, she forwards that information to the local law

enforcement agency.

{¶8} Skelly received three CyberTipline Reports regarding the same I.P.

address. They each related to a CyberTip Snapchat had submitted to NCMEC of

“apparent violations” of federal criminal statutes involving child pornography. The State

introduced two of them, Exhibits 19 and 20. Each Exhibit stated the time of the reported

incident, which, according to Skelly, was when the user “saved, shared, or uploaded” the

content. Each Exhibit also listed the reported user’s account information, including date

of birth, email address, username, and I.P. address. The trial court overruled Appellant’s

objections to these Exhibits.

{¶9} Exhibits 19 and 21 each included digital files that contained images and/or

videos of sexual material involving a prepubescent child.

PAGE 3 OF 19

Case No. 2024-T-0076 {¶10} Skelly said that upon receiving the Reports, she had a grand jury subpoena

issued to Charter Communications, the internet service provider for the I.P. address

shown in the Reports. It demanded production of subscriber information for that I.P.

address. The trial court overruled Appellant’s objection to this testimony.

{¶11} Skelly stated that in response to the subpoena, Charter produced records

for the suspected I.P. address with a sworn certification that they were “records kept in

the ordinary course of the . . . regularly conducted business of Charter Communications”

and generated by Charter Communications. They were identified and marked as Exhibit

20. The document indicated that Appellant was the subscriber and detailed his home

address, phone number, and email address. After receiving this information, Skelly

forwarded the case to the Howland Township Police Department for further investigation.

{¶12} The State called Detective Nicholas Brancaccio of the Howland Township

Police Department. Detective Brancaccio said that he received an email from the Ohio

Internet Crimes Against Children Task Force in March 2024 with information about

Appellant. He verified Appellant’s residence and obtained a search warrant for all

electronic devices within Appellant’s residence.

{¶13} On May 30, 2024, he searched Appellant’s residence and told Appellant

that the search was for CSAM. Appellant said that any such material would be on his

iPad. He also said that his girlfriend had discovered CSAM on one of his devices about a

year prior. Appellant disclosed the password to unlock his devices. Officers recovered

Appellant’s cell phone, an iPad, a hard drive, and a flash drive.

{¶14} Detective Brancaccio examined the iPad and iPhone and found the devices

contained photographs of Appellant and his two-year-old daughter while Appellant was

PAGE 4 OF 19

Case No. 2024-T-0076 engaging in sexual acts and in a state of nudity. The State introduced these images as

Exhibits 1 and 2. Detective Brancaccio said that the background, flooring, and contents

of the images indicated they were taken at Appellant’s residence. Detective Brancaccio

also discovered five videos depicting Appellant engaging in bestiality with the family dog.

The State introduced these videos as Exhibits 7-11. Objections to all seven of these

Exhibits and their use were overruled. Detective Brancaccio also submitted the devices

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1785, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-addicott-ohioctapp-2025.