State v. Snyder

2025 Ohio 216
CourtOhio Court of Appeals
DecidedJanuary 27, 2025
DocketCA2024-04-023
StatusPublished

This text of 2025 Ohio 216 (State v. Snyder) 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. Snyder, 2025 Ohio 216 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Snyder, 2025-Ohio-216.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

STATE OF OHIO, :

Appellee, : CASE NO. CA2024-04-023

: OPINION - vs - 1/27/2025 :

MARK SNYDER, :

Appellant. :

CRIMINAL APPEAL FROM WARREN COUNTY MUNICIPAL COURT Case No. 24CRB000056

David P. Fornshell, Warren County Prosecuting Attorney, and Kirsten A. Brandt, Assistant Prosecuting Attorney, for appellee.

Craig A. Newburger, for appellant.

M. POWELL, J.

{¶ 1} Mark Snyder appeals his conviction in the Warren County Municipal Court

for violation of a protection order. For the reasons set out below, we affirm the judgment

of trial court. Warren CA2024-04-023

{¶ 2} Snyder and the victim were in a five-year relationship before they broke up.

On October 30, 2023, the victim obtained a protection order against Snyder. The order

prohibited Snyder from, among other things, initiating or having any contact with the

victim. Snyder was verbally advised of and served with a copy of the order by law

enforcement in November of 2023. However, on January 25, 2024, the victim received a

text message from Snyder's phone number which stated, "I miss you."1

{¶ 3} After the victim reported the foregoing to law enforcement, Snyder was

charged with violating the protection order. The criminal complaint stated that "on or

about 01/25/2024" Snyder "violated [a] Warren County CPO . . . by sending a text

message, 'I miss you' to ex-girlfriend, the victim, petitioner of the CPO." On February 12,

2024, a public defender was appointed to represent Snyder, and a trial was scheduled

for March 5, 2024. On the day of trial, Snyder sought a continuance, and the trial was

continued to April 2, 2024. A new attorney was later retained by Snyder on March 19,

2024 and substituted as Snyder's counsel of record.

{¶ 4} On the day of the rescheduled trial, Snyder's new attorney orally moved to

again continue the trial, noting that while aware of the trial date when she substituted as

counsel, discovery was received from the State only days prior. In addition, Snyder

purportedly needed time to obtain cell phone records to support his claim that the victim

had fabricated the text message the charges were based on. The trial court denied the

motion for a continuance. However, Snyder had copies of his cell phone records used in

a concurrent civil case between Snyder and the victim. These copies were not certified,

appeared copied and pasted from another source, and contained handwritten notes.

1. Snyder argues in his second assignment of error that "the State failed to introduce any testimony regarding . . . any date being observable on the text" in the video presented at trial." However, the video, which was admitted into evidence, clearly shows that above the at issue text is a date of January 25, 2024 with a timestamp of 9:25 PM. -2- Warren CA2024-04-023

Nonetheless, the trial court accepted the copies and scratched out the notes before

admitting them into evidence.

{¶ 5} At trial, the victim testified that Snyder sent her the text message. The victim

had deleted Snyder's contact information from her phone, but Snyder admitted to using

the phone number associated with the text. To show that the text message was not

fabricated or altered, the State presented a video of the victim accessing her phone, the

disputed text message, and the contact information associated with the message. The

video was taken approximately one week before the trial and months after the message

had been originally sent. Snyder argued this delay in recording the video demonstrated

its unreliability. In addition to the victim's testimony, the investigating officer also testified

to personally viewing the text message but acknowledged no phone records regarding

the message were obtained.

{¶ 6} During his testimony, Snyder denied sending the text message and

contended it was fabricated. In support of this contention, Snyder argued, in summary:

(1) his cell phone records showed no text messages from his phone to the victim on the

date in question; (2) the victim's video showed Snyder's phone number was associated

with an Apple iCloud account / email (bearing similarities to Snyder's name) that he did

not use; (3) there were two iPhones on his AT&T account—his Apple iPhone as well as

a second iPhone—and the second iPhone was in possession of the victim and her son

on the date of the text message was sent to the victim; (4) the second phone could have

had access to his Apple iCloud account and sent the text message (the victim testified

she did not recognize a photo of the second phone that was presented at trial); and (5)

the victim fabricated the message in retaliation of his filing a civil suit against her.

{¶ 7} After the bench trial, the court found Snyder guilty of violating the protection

order and sentenced him in accordance with law. Snyder now appeals.

-3- Warren CA2024-04-023

{¶ 8} FIRST ASSIGNMENT OF ERROR. THE TRIAL COURT ERRED TO

APPELLANT'S PREJUDICE WHEN IT DENIED HIS MOTION TO CONTINUE THE

TRIAL IN ORDER TO ACQUIRE EXCULPATORY EVIDENCE IN VIOLATION OF THE

DUE PROCESS CLAUSE OF THE UNITED ST ATES CONSTITUTION.

{¶ 9} First, Snyder argues on appeal that the trial court abused its discretion in

refusing to continue the April 2, 2024 bench trial to afford him time to obtain his cell phone

records and support his claim that he did not send the offending text message. We review

a trial court's decision to grant or deny a continuance for an abuse of discretion. Ostigny

v. Brubaker, 2024-Ohio-384, ¶ 20 (12th Dist.). An abuse of discretion implies the trial

court's attitude is unreasonable, arbitrary, or unconscionable. Blakemore v. Blakemore,

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

{¶ 10} The trial court did not abuse its discretion in denying the request for a

continuance. Snyder and his attorneys were well aware that the sole basis of the

complaint was the January 25, 2024 text message. While the State provided Snyder's

retained counsel with discovery mere days before trial, counsel was aware of the trial

date upon entering the case, and nothing in the record indicates the discovery was

voluminous or complex. In addition, the trial date had already been continued at Snyder's

request (also on the day trial was set to occur). Ultimately, Snyder's retained counsel had

enough time to get up to speed on the nature of the case, and Snyder had more than

enough time to get his phone records in any format he desired. Even if we were inclined

to conclude the trial court abused its discretion, we fail to see any prejudice to Snyder

because he was still able to present copies of the records or information he compiled at

trial (regardless of their condition or trustworthiness). Snyder does not speak to this on

appeal.

{¶ 11} We overrule this assignment of error.

-4- Warren CA2024-04-023

{¶ 12} SECOND ASSIGNMENT OF ERROR. THE EVIDENCE WAS

INSUFFICIENT AS A MATTER OF LAW AND/OR GOES AGAINST THE MANIFEST

WEIGHT OF THE EVIDENCE TO SUSTAIN DEFENDANT'S CONVICTIONS.

{¶ 13} Next, Snyder argues his convictions were not supported by sufficient

evidence and were against the manifest weight of the evidence because (1) the video of

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Bluebook (online)
2025 Ohio 216, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-snyder-ohioctapp-2025.