State v. Wilcox

Summary

The Ohio Supreme Court held that the witness’s statements captured on body‑camera video before the suspect’s apprehension were nontestimonial, so their admission did not violate the Sixth Amendment Confrontation Clause; the Court reversed the Court of Appeals judgment and remanded for the lower court to decide the admissibility of those statements under the Ohio Rules of Evidence and to conduct a harmless‑error analysis.