Ohio Supreme Court

State v. Grad

December 9, 20242024 Ohio 5710

Summary

The Ohio Supreme Court reversed the Ninth District Court of Appeals, holding that the trial court erred by refusing to hold a hearing on Grad’s motion for leave to file a new‑trial motion, and remanded for such a hearing. The Court clarified that post‑trial scientific studies can qualify as newly discovered evidence when they represent a significant change in scientific knowledge, and that a hearing is required when a defendant makes a prima facie showing of being unavoidably prevented from discovering that evidence.