Toledo v. Wyse

2022 Ohio 1979, 190 N.E.3d 1232
CourtOhio Court of Appeals
DecidedJune 10, 2022
DocketL-21-1126
StatusPublished
Cited by1 cases

This text of 2022 Ohio 1979 (Toledo v. Wyse) 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
Toledo v. Wyse, 2022 Ohio 1979, 190 N.E.3d 1232 (Ohio Ct. App. 2022).

Opinion

[Cite as Toledo v. Wyse, 2022-Ohio-1979.]

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

State of Ohio/City of Toledo Court of Appeals No. L-21-1126

Appellant Trial Court No. CRB-20-03413

v.

Malachi Wyse DECISION AND JUDGMENT

Appellee Decided: June 10, 2022

*****

David Toska, City of Toledo Chief Prosecuting Attorney, and Christopher D. Lawrence, Assistant Prosecuting Attorney, for appellant.

Michael H. Stahl, for appellee.

DUHART, J.

{¶ 1} Appellant, the city of Toledo (“the City”), appeals from a judgment entered

by the Toledo Municipal Court granting a motion to dismiss filed by appellee, Malachi

Wyse. For the reasons that follow, we reverse the judgment of the trial court. Statement of the Case

{¶ 2} On April 6, 2020, Wyse was charged under R.C. 3701.352 for violating a

“stay at home” order that had been issued by the Ohio Health Department. On June 1,

2020, Wyse, through counsel, filed a motion for discovery seeking, inter alia, “[a] written

list of the names and addresses of all witnesses that the City intends to call in its case in

chief, or reasonably anticipates calling in rebuttal or surrebuttal.” On July 2, 2020, the

City responded, stating that it intended to call arresting Officer Alexander J. Simpson as a

witness. On July 10, 2020, Wyse filed a motion for supplemental discovery, stating that

“based on the April 6, 2020 police report * * * which states that Officer Alexander

Simpson’s BWC was activated during the encounter, the Defense would request any and

all video recording from Officer Simpson’s BWC as well as any and all BWC recordings

from other police officers that recorded video of the alleged incident as well as any and

all other evidence collected in this case but not yet presented to the Defendant.”

{¶ 3} On July 14, 2020, the City filed a supplemental response to Wyse’s request

for discovery, wherein it again named Officer Simpson as the sole witness that the City

intended to call as a witness. This time, however, the City indicated that, in addition to

the discovery packet, body camera evidence had been provided. On July 16, 2020, Wyse

filed a motion for preservation and production of exculpatory evidence, in which he

requested an order directing the prosecution to preserve any and all evidence related to

his case, including “a bag of snacks” that was allegedly confiscated by the Toledo police.

2. According to Wyse, both the body-cam recordings and the confiscated food items would

demonstrate that Wyse had gone grocery shopping and, thus, had been performing an

essential activity, which was not in violation of the “stay at home” order, at the time of

his arrest. Also on July 16, 2020, Wyse filed a motion for supplemental discovery

requesting “all body-cam video recordings from the alleged incident.” In this motion, he

noted that the body-cam footage from Officer Simpson merely recorded events that

occurred following Wyse’s arrest, and not “the critical events leading up to his arrest.” In

addition, he requested “the specific gloves and mask worn by Mr. Wyse at the time of his

arrest as well as the grocery bag and contents therein (including but not limited to a bottle

of tea and packaged snacks) that he was carrying at the time of his arrest” and any “store

receipts that were in the bag with the food items.” The City failed to respond to the

July 16, 2020 motion for supplemental discovery. On October 16, 2020, Wyse filed a

motion to compel the requested discovery. Finally, on April 1, 2021, Wyse filed a

motion to dismiss, arguing that his due process rights had been violated. Several hearings

took place in connection with the outstanding motions. During a hearing held on

October 21, 2020, the City prosecutor stated that the state had “made requests and put

forth [to the defense] all body cam that was available that day.” He further stated that

“there is no other [body camera] evidence that we are in possession of to give.” During a

hearing held on February 25, 2021, the City prosecutor stated, “At this point the

information that I have is that Officer Simpson is the only person with a functioning body

3. camera that day.” The trial court ultimately granted the motion to dismiss in a judgment

entry filed on June 22, 2021.

{¶ 4} In the judgment entry, the trial court relevantly concluded that Wyse’s

property, including “groceries, mask, and gloves,” had been confiscated by police. In

addition, the court stated:

In the case at hand, the court finds that the [video] evidence that was

either lost, destroyed, or unproduced by the state could certainly be

exculpatory. * * * The defendant’s personal property seized and lost on the

night in question likewise would be exculpatory in proving that he was

engaged in the lawful activity of returning from the grocery store at the

time of the arrest.

The court further finds that both the video evidence and the personal

property evidence are unique and not obtainable by other means. As such,

the court finds that defendant’s Due Process rights were violated when the

state destroyed, lost, or failed to produce the evidence that the defendant

properly, repeatedly, and specifically requested.

* * * In the case at hand, the Court does not find that the individual

officers acted in bad faith. However, the officers in either failing to activate

their body worn cameras, or in failing to preserve the recorded encounter,

4. or in failing to locate the preserved video evidence stored in the Cloud is

troubling to the Court.

Add to it, the failure to secure and inventory the defendant’s

personal property upon his arrest and there is a complete failure of the

officers in following the mandated procedures from their own department.

This leaves the defendant without any objective evidence of the incident in

question. When a police department embraces the video technology in

question, and adopts specific policies to its use and retention, it assumes the

responsibility to follow its own mandates. The responsibility to preserve

and produce evidence is of paramount importance to justice being served

for both sides.

Given the totality of the circumstances, the Court finds that the

appropriate sanction is the granting the defendant’s motion to dismiss.

Anything less would be unjust.

(Emphasis added.)

{¶ 5} On June 24, 2021, the City timely filed an appeal from the judgment.

Statement of the Facts

{¶ 6} On April 6, 2020, Officer Alexander Simpson arrested Wyse for violating

the Ohio Health Department “stay at home” order. Officer Anthony Vines, who was

present on the scene, testified that there was a “mass gathering of people,” “quite a big

5. crowd,” with “multiple officers” present. The arresting officer, Officer Alexander

Simpson, testified that there were between three and five officers within 25 feet of Wyse

at the time of his arrest. Officer Vines testified that he did not witness the arrest. The

other officers were not named in the police report and neither Officer Simpson nor

Officer Vines could testify as to their identities.

{¶ 7} Officer Simpson testified that each officer on the scene should have been

equipped with a body camera, excluding specialty units and sergeants, and that, pursuant

to Toledo Police Department policy, any interaction between an officer and a civilian

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2022 Ohio 1979, 190 N.E.3d 1232, Counsel Stack Legal Research, https://law.counselstack.com/opinion/toledo-v-wyse-ohioctapp-2022.