State v. Lammie

2026 Ohio 1109
CourtOhio Court of Appeals
DecidedMarch 30, 2026
Docket3-25-11
StatusPublished

This text of 2026 Ohio 1109 (State v. Lammie) 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. Lammie, 2026 Ohio 1109 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Lammie, 2026-Ohio-1109.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT CRAWFORD COUNTY

STATE OF OHIO, CASE NO. 3-25-11 PLAINTIFF-APPELLEE,

v.

KEVIN LAMMIE, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

Appeal from Crawford County Common Pleas Court Trial Court No. 24-CR-0333

Judgment Affirmed

Date of Decision: March 30, 2026

APPEARANCES:

Christopher Bazeley for Appellant

Daniel J. Stanley for Appellee Case No. 3-25-11

ZIMMERMAN, P.J.,

{¶1} Defendant-appellant, Kevin Lammie (“Lammie”), appeals the April 24,

2025 judgment entry of sentencing of the Crawford County Court of Common Pleas.

For the reasons that follow, we affirm.

{¶2} On November 19, 2024, the Crawford County Grand Jury indicted

Lammie on Count One of felonious assault in violation of R.C. 2903.11(A)(1),

(D)(1)(a), a second-degree felony; Count Two of strangulation in violation of R.C.

2903.18(B)(3), (C)(3), a fourth-degree felony; and Count Three of domestic

violence in violation of R.C. 2919.25(A), (D)(2), a misdemeanor of the first degree.

Lammie appeared for arraignment on November 21, 2024, and entered pleas of not

guilty.

{¶3} The case proceeded to a two-day jury trial on April 17, 2025. On April

18, 2025, the jury found Lammie guilty of felonious assault and domestic violence

and not guilty of strangulation.

{¶4} On April 24, 2025, the trial court sentenced Lammie to an indefinite

mandatory minimum term of six years to a maximum term of nine years in prison

on Count One (felonious assault). The trial court further sentenced Lammie to 180

days in jail on Count Three (domestic violence), to be served concurrently with the

sentence imposed on Count One.

-2- Case No. 3-25-11

{¶5} On May 8, 2025, Lammie filed his notice of appeal. He raises two

assignments of error for our review.

First Assignment of Error

The Trial Court Erred By Allowing Irrelevant Evidence Of Lammie’s Prior Convictions Under Evid.R. 609.

{¶6} In his first assignment of error, Lammie argues that the trial court

abused its discretion by admitting evidence of his prior convictions for the purpose

of impeaching his credibility. Specifically, Lammie contends that the trial court

erred by failing “to engage in the five-factor [Evid.R. 609] analysis” and determine

“whether each factor favor[ed] admission or exclusion of the evidence.”

(Appellant’s Brief at 3). Lammie further argues that the trial court erred by failing

to “advise the jury of the limited purpose it allowed the evidence in.” (Id.).

Standard of Review

{¶7} Evid.R. 609 governs impeachment by evidence of prior convictions and

provides, in pertinent part, as follows:

(A) General rule. For the purpose of attacking the credibility of a witness:

...

(2) Notwithstanding Evid.R. 403(A), but subject to Evid.R. 403(B), evidence that the accused has been convicted of a crime is admissible if the crime was punishable by death or imprisonment in excess of one year pursuant to the law under which the accused was convicted and if the court determines that the probative value of the evidence outweighs the danger of unfair prejudice, of confusion of the issues, or of misleading the jury.

-3- Case No. 3-25-11

(3) Notwithstanding Evid.R. 403(A), but subject to Evid.R. 403(B), evidence that any witness, including an accused, has been convicted of a crime is admissible if the crime involved dishonesty or false statement, regardless of the punishment and whether based upon state or federal statute or local ordinance.

(B) Time limit. Evidence of a conviction under this rule is not admissible if a period of more than ten years has elapsed since the date of the conviction or of the release of the witness from the confinement, or the termination of community control sanctions, post-release control, probation, parole, or judicial release imposed for that conviction, whichever is the later date, unless the court determines, in the interests of justice, that the probative value of the conviction supported by specific facts and circumstances substantially outweighs its prejudicial effect. . . .

Evid.R. 609(A), (B).

{¶8} Under Evid.R. 609, a trial court has broad discretion to determine the

extent of the admissibility of prior convictions for impeachment purposes. State v.

Brown, 2003-Ohio-5059, ¶ 27. Therefore, we review the trial court’s determination

under Evid.R. 609 for an abuse of discretion. An abuse of discretion implies that

the trial court’s attitude is unreasonable, arbitrary, or unconscionable. Blakemore

v. Blakemore, 5 Ohio St.3d 217, 219 (1983).

{¶9} “When an accused testifies at trial, Evid.R. 609(A)(2) allows the state

to impeach the accused’s credibility with evidence that the accused was convicted

of an offense punishable by imprisonment in excess of one year and if the court

determines that the probative value of the evidence outweighs the danger of unfair

prejudice, of confusion of the issues, or of misleading the jury.” State v. Bryan,

-4- Case No. 3-25-11

2004-Ohio-971, ¶ 132. In making this determination, the trial court should consider

the following factors: (1) the nature of the crime, (2) recency of the prior conviction,

(3) similarity between the crime for which there was a prior conviction and the crime

charged, (4) importance of the defendant’s testimony, and (5) centrality of the

credibility issue. State v. Goney, 87 Ohio App.3d 497, 501 (2d Dist. 1993).

Analysis

{¶10} In this case, Lammie’s prior convictions include a burglary conviction

in 2013 (and the community control sanctions terminated in 2017); an aggravated-

arson conviction in 2013 (and Lammie was released from confinement in 2020);

and an aggravated-possession-of-drugs conviction in 2020.

{¶11} Prior to Lammie taking the witness stand to testify at trial, Lammie

objected to evidence of his prior convictions of burglary and aggravated arson being

used for impeachment purposes. Lammie argued that these convictions are older

than ten years and should be excluded. Notably, Lammie did not make any

argument that the prior convictions should be excluded because the danger of unfair

prejudice outweighs the probative value of the evidence.

{¶12} The trial court overruled Lammie’s objection, noting that the ten-year

time period set forth in Evid.R. 609(B) does not commence until the witness is

released from confinement or the community control sanctions are terminated.

Moreover, the trial court found that Lammie’s aggravated-possession-of-drugs

conviction in 2020 was within the ten-year time limit. The trial court determined

-5- Case No. 3-25-11

that “all three are admissible. They’re all within the 10-year time limit.” (Apr. 18,

2025 Tr. at 375). As to the danger of unfair prejudice, the trial court stated, “And I

do not find that Rule 403 would mandate that I exclude any of those convictions.”

(Id.).

{¶13} During cross-examination, the following testimony was elicited from

Lammie regarding his prior felony convictions.

Q. Okay. Now, I want to go a little bit more in your background. You said that you had some problems in Toledo?

A. Yeah.

Q. Fair to say that you were convicted of a burglary in 2012 or 2013 in Toledo?

A. No, ’11.

[Defense Counsel]: We object.

THE COURT: Overruled. We discussed this before - - before.

A.

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Related

State v. Topping
2012 Ohio 5617 (Ohio Court of Appeals, 2012)
State v. Goney
622 N.E.2d 688 (Ohio Court of Appeals, 1993)
State v. Brown
621 N.E.2d 447 (Ohio Court of Appeals, 1993)
State v. Essinger, Unpublished Decision (11-10-2003)
2003 Ohio 6000 (Ohio Court of Appeals, 2003)
State v. Long
372 N.E.2d 804 (Ohio Supreme Court, 1978)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
State v. Biros
678 N.E.2d 891 (Ohio Supreme Court, 1997)
State v. Bailey
2022 Ohio 4407 (Ohio Supreme Court, 2022)
Oberlin v. Akron Gen. Med. Ctr.
2001 Ohio 248 (Ohio Supreme Court, 2001)
State v. Day
2025 Ohio 5625 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 1109, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lammie-ohioctapp-2026.