State v. Donaldson

2026 Ohio 477
CourtOhio Court of Appeals
DecidedFebruary 13, 2026
DocketL-24-1246
StatusPublished

This text of 2026 Ohio 477 (State v. Donaldson) 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. Donaldson, 2026 Ohio 477 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Donaldson, 2026-Ohio-477.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio Court of Appeals No. {48}L-24-1246

Appellee Trial Court No. CR0202302666

v.

Christopher Donaldson DECISION AND JUDGMENT

Appellant Decided: February 13, 2026

*****

Julia R. Bates, Lucas County Prosecuting Attorney, and, Lorrie J. Rendle, Assistant Prosecuting Attorney, for appellee.

Catherine Meehan, for appellant.

***** OSOWIK, J.

{¶ 1} This is an appeal of a September 27, 2024 judgment of the Lucas County

Court of Common Pleas, finding appellant guilty, following a jury trial, on one count of

endangering children, in violation of R.C. 2919.22(A), a felony of the third degree, and

sentencing appellant to a 12-month term of incarceration. For the reasons set forth below,

this court affirms the judgment of the trial court. {¶ 2} Appellant, Christopher Donaldson, sets forth the following four assignments

of error:

I: The trial court erred in denying appellant’s motion to dismiss as untimely. II: The trial court erred in permitting expert testimony when the State of Ohio failed to comply with Crim.R. 16(K) and no good cause was shown to modify the time requirements, causing prejudice to appellant. III: Appellant’s conviction was not supported by sufficient evidence. IV: Appellant’s conviction was against the manifest weight of the evidence.

Case Background

{¶ 3} The following facts are derived from the record of evidence presented to the

trial court. This case arises from an incident that occurred on October 17, 2023, during

which appellant, while serving as the sole caregiver of C.D., his four-month-old infant

son and the victim in this case, forcefully handled C.D. in such a way that he fractured

C.D.’s right humerus. Appellant does not deny the occurrence, but rather, denies bearing

legal culpability in connection to same.

{¶ 4} On October 17, 2023, A.K., C.D.’s mother, left C.D. in appellant’s care upon

leaving for work as a Door Dash delivery driver. Shortly after leaving home, A.K.

stopped at a service station to purchase gas and supplies for work. While getting gas,

A.K. received a frantic mobile phone call from appellant. Appellant told A.K. that upon

picking up C.D., while he was fussing, appellant heard something “pop” in C.D., and

C.D. needed to be taken to the emergency room.

2. {¶ 5} A.K. immediately returned home, observed C.D.’s right arm dangling in an

unusual way, and determined that C.D. was injured. A.K. took C.D. to the emergency

room for medical treatment, while appellant remained at home.

{¶ 6} Upon evaluating C.D. at the hospital, medical personnel tested C.D.’s right

arm to first determine if C.D. may possibly suffer from a condition referred to as

“nursemaid’s elbow” which, if present, may have been a benign cause of C.D.’s injury.

Upon testing C.D., it was determined that C.D. did not have “nursemaid’s elbow” and it

was ruled out as the cause of the injury. Upon concluding examination and treatment of

C.D., emergency medical personnel ultimately determined that the origin of C.D.’s injury

was not benign. Accordingly, the Toledo Police Department was notified of the incident

and commenced an investigation into the cause of the infant’s injury.

{¶ 7} Detective Gawrych (“Gawrych”) was assigned to investigate the case.

When interviewing appellant, appellant acknowledged to Gawrych that C.D. had been

quite fussy, so appellant grabbed C.D. by the hands, lifted him up, heard a “pop”, and

then noted that C.D.’s level of fussiness worsened. The police investigation ultimately

concluded that appellant fractured C.D.’s right elbow when forcefully handling him.

Procedural History

{¶ 8} On October 26, 2023, appellant was indicted on one count of endangering

children, in violation of R.C. 2919.22(A), a felony of the third degree. Appellant retained

counsel and pled not guilty. On November 2, 2023, appellant requested a bill of

particulars. On November 21, 2023, the State responded to appellant’s bill of particulars,

3. detailing that the offense occurred on October 17, 2023, between 6:15p.m. and 6:30p.m.,

directed appellant to the police reports prepared in the course of the investigation into the

incident, and offered appellant inspection of all non-protected file materials at a mutually

agreed upon time. Appellant declined to arrange for an inspection of the file materials.

{¶ 9} On February 21, 2024, in accord with Crim.R. 16, the State provided

appellant’s counsel with the expert report prepared by Dr. Randall Schlievert

(“Schlievert”), its’ expert witness. The report determined, in relevant part, “Overall, the

right elbow fracture is concerning for likely non-accidental trauma.”

{¶ 10} The week prior to trial, Schlievert learned that there was video footage of

appellant demonstrating to Gawrych how appellant purported to have been handling C.D.

just prior to the injury occurring. As a cautionary step, to determine whether the video

footage may modify his above-quoted initial conclusion regarding the cause of C.D.’s

injury, Schlievert reviewed the footage. On August 8, 2024, after reviewing the footage,

Schlievert prepared a one-page supplement to his initial report, determining that the video

footage did not alter, but rather, reinforced his initial conclusion, finding, in relevant part,

What [appellant] demonstrated [in the video re-enactment] doesn’t put disproportionate force on the right or left elbow [such that the injury could not have occurred if appellant handled C.D. as he purported to have in the video re-enactment]. Hence, there was disproportionate force put on [C.D.’s] right elbow, which is not consistent with what [appellant] demonstrated and is only reasonably consistent with more extreme non- daily forces that were used [by appellant upon C.D.] that day.

4. {¶ 11} On August 9, 2024, the one-page supplement to the initial report,

consistently finding the injury was caused by non-accidental trauma inflicted by

appellant, was provided to appellant’s counsel.

{¶ 12} On August 13, 2024, the case was scheduled for jury trial. On the

afternoon of August 12, 2024, the day prior to trial, appellant filed a motion to dismiss,

premised upon generic allegations of a defective indictment, and also a motion in limine

to exclude Schlievert’s testimony regarding the supplement to the report based upon the

undisputed lateness of the congruous one-page supplement.

Motion to Dismiss and Motion in Limine Regarding Schlievert

{¶ 13} On August 13, 2024, at the onset of the trial proceedings, the trial court first

heard opposing arguments on the two above-described pending motions. The trial court

first denied appellant’s motion to dismiss as untimely, finding that appellant failed to

demonstrate any defects in the indictment, as will be discussed in detail below, so as to

arguably justify the lateness of the motion.

{¶ 14} With respect to the motion in limine, all parties acknowledged that the

receipt of the one-page supplement to the initial report, with consistent causation

findings, was not furnished to appellant 21 days prior to trial, as required by Crim.R.

16(K). Accordingly, to rectify the untimely discovery issue, the trial court offered

appellant a continuance of the trial, and indicated that it would reschedule the trial in

conformity with the Crim.R. 16(K) timing requirements.

5.

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Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 477, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-donaldson-ohioctapp-2026.