Wednesday, April 23, 2025
State of Ohio v. Dorian L. Crawl, Case No. 2024-0532
Second District Court of Appeals (Montgomery County)
State of Ohio v. Edward Balmert, Case No. 2024-0669
Ninth District Court of Appeals (Lorain County)
State of Ohio v. Mamadou Diaw, Case No. 2024-1083
Tenth District Court of Appeals (Franklin County)
Could Stalking Conviction Be Partly Based on Non-Threatening Comments on Instagram?
State of Ohio v. Dorian L. Crawl, Case No. 2024-0532
Second District Court of Appeals (Montgomery County)
ISSUE: To support a criminal conviction for stalking, can non-threatening comments to social media posts be considered as conduct knowingly made to cause harm or distress if the individuals have no existing relationship and the poster never indicates the comments are unwanted or threatening?
BACKGROUND:
The crime of menacing by stalking is defined by Ohio law as engaging in a pattern of conduct where the offender knowingly leads a person to believe they are in physical harm or will cause the person mental distress. A “pattern of conduct” is defined as two more actions closely related in time.
In May 2022, a woman identified in court records as “A.P.” was celebrating her 29th birthday. She posted a photo on her Instagram account and wrote, “29, be good to me.” Her Instagram account wasn’t private, so anyone could see and comment on her post.
Dorian Crawl went to grade school with A.P. Years later, in 2020, he sent A.P. a friend request on Instagram. A.P. said she had the account since high school but didn’t use it frequently until 2022. She said she didn’t see Crawl’s 2020 friend request. Crawl and A.P. acknowledged they didn’t know each other well in grade school, and she recalled last seeing him when she was 12 or 13 years old.
Crawl commented on A.P.’s birthday post by first sending a “sad emoji.” Then he wrote, “Happy Birthday, baby girl. I love you. Hope we can see each other sometime soon.” A.P. didn’t respond to the messages. A week later, A.P. posted a video on her Instagram account. Crawl commented on the post, “Where is this (A.P.)? Is this your house, boo?” A.P. didn’t respond.
Man Visits Former Classmate’s Home
About a month later, Crawl appeared at the front door of the apartment A.P. lived in with her 9-year-old daughter. Crawl knocked on the unlocked door, and A.P. went to the door, looked through the peephole, and saw him. She asked who was there, and he responded, “It’s Dorian. I’m (A.P.’s) friend. I’m here to see her.” A.P. turned the deadbolt to lock the door. Crawl turned the doorknob.
A.P. ran to the back of the apartment where her daughter was located. She put her daughter in a closet and called the police. A West Carrollton police officer arrived at the apartment. Crawl had left, and the officer spoke to A.P. The officer reported that A.P. was visibly upset, crying, and nervous, as if something was going to happen to her.
The officer contacted Crawl, who said he knew A.P. from grade school, but they were never friends and never talked in school. He told the officer he was attracted to A.P., believed there was a potential for a relationship with her, and was attempting to contact A.P. to “follow up” on that. Crawl noted that A.P. didn’t provide him with her address, and that he researched and found it online. Crawl told the officer he tried to stay calm during the visit and didn’t like the way she reacted to him.
In August 2022, Crawl was charged with menacing by stalking in violation of R.C. 2903.211(A)(1), a first-degree misdemeanor. He pleaded not guilty, and a Miamisburg Municipal Court judge conducted a bench trial. The judge found him guilty, sentenced him to 180 days in jail, with 178 days suspended, and placed him on two years of probation. He was also ordered not to have contact with A.P. for two years. The judge granted Crawl’s request to stay his sentence until the appeal of his conviction was complete.
Crawl appealed to the Second District Court of Appeals, which affirmed the trial court’s decision.
Crawl appealed the Second District’s decision to the Supreme Court of Ohio, which agreed to hear the case.
Social Media Comments Not Proven To Harm Victim, Offender Argues
The crime of stalking involves engaging in a pattern of conduct that may cause the victim to be in fear or distress, Crawl explains. He was charged, in part, based on the social media comments he made to A.P. He argues those comments can’t be considered part of the pattern of conduct that led to his conviction. He notes he only appeared at A.P.’s house one time, and he sent no further messages to her after that date.
R.C. 2903.211(A)(1) states that no person by engaging in a pattern of conduct “shall knowingly cause another person to believe the offender will cause physical harm” or cause mental distress. Crawl asserts that when he sent the Instagram comments, there was no evidence that he “knowingly” believed those comments would cause A.P. to be in fear or distress. He notes that R.C. 2901.22 defines four mental states attached to crimes, describing actions done purposely, knowingly, recklessly, or negligently. “Knowingly” requires the offender to have an awareness of the probability that his conduct will cause a certain result. Crawl notes that Ohio courts have emphasized the offender has to know the result is “probable,” not just “possible.”
The comments to A.P. may have been awkward since the two didn’t have a relationship, Crawl asserts, but they in no way were threatening or an attempt to cause mental distress. He notes that A.P. never responded to him, didn’t block him, and kept her Instagram account public afterward. He warns that if his conviction is upheld, anyone engaging in the simple act of posting on social media in a non-threatening manner could be accused of stalking based on the reactions of the person who posted.
Crawl explains that past relationships have been used in other cases to provide context in which actions that seem non-threatening can be considered knowing acts causing fear or distress. He points to a 1994 case (State v. Woodgeard) in which a man was convicted of stalking by driving by the victim’s house three times. When evidence was provided that he had previously assaulted the victim and made harassing telephone calls to her, it provided the context that made it clear the seemingly innocent act of driving past the house was actually an attempt to knowingly cause the victim to feel mental distress.
Because there was no past relationship between Crawl and A.P., he argues there is no evidence that his posts would have the probable effect of causing A.P. fear or distress. Because the posts weren’t part of a pattern of conduct knowingly undertaken to cause A.P. fear or distress, his stalking conviction should be overturned, he concludes.
Offender Knew Actions Would Cause Distress, Law Director Asserts
Crawl engaged in a pattern of conduct, sending bizarre messages to A.P. that were alarming and distressing, and subsequently appeared at her home and attempted to force entry, the West Carrollton law director asserts. His messages were strangely endearing, calling her “baby girl” and “boo,” and proclaiming to love her, even though they have never spoken to each other, the law director notes. Crawl knew his actions would cause A.P. to be in fear or suffer mental distress, the law director asserts.
Crawl’s appeal challenges the sufficiency of the evidence against him, the law director notes. When this type of challenge is made, an appeals court does not ask whether the evidence should be believed, but rather, if believed, would the evidence “convince the average person? of the defendant’s guilt beyond a reasonable doubt?” the law director’s brief states. The trial court found the key aspects of the crime of menacing by stalking were proved by the prosecution, and the Second District correctly affirmed Crawl’s conviction, the law director maintains.
The law director explains that under the “knowingly” standard, the offender doesn’t have to predict the “precise consequences” of his conduct, only that the consequences were foreseeable. Whether the consequences are foreseeable is based on the surrounding facts and circumstances, the law director notes. Crawl had no contact with A.P. until he started sending her direct messages on Instagram, which were overly affectionate, the law director argues. And it is foreseeable that calling a stranger pet names would cause distress, the law director adds.
The law director notes that A.P. testified at Crawl’s trial that he sent her strange messages on social media, and when he showed up at her door, she “instantly freaked out.” Afterward, she installed cameras around her apartment, started looking for another place to live, made sure she had her phone on when she arrived home, with her boyfriend staying at her apartment more often. She said she had intentions of reaching out to a doctor because of her mental distress. The law director argues Crawl’s actions should be viewed in totality and they constitute a pattern of conduct that could cause A.P. fear and mental distress. Crawl wants the Supreme Court to look at the social media comments in isolation, but the law director maintains that the stalking charge is based on the entirety of his actions.
Attorney General To Participate in Case
An amicus curiae brief supporting the law director’s position was submitted by the Ohio Attorney General’s Office. The attorney general’s office will participate in the case and share oral argument time with the law director.
– Dan Trevas
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Dorian L. Crawl: Arvin Miller, millera@mcohio.org
Representing the State of Ohio on behalf of the West Carrollton Law Director’s Office: Mark Webb, mwebb@smw-law.com
Representing the Ohio Attorney General’s Office: T. Elliot Gaiser, thomas.gaiser@ohioago.gov
Did Marijuana Metabolites Impair Man’s Driving, Injuring State Trooper?
State of Ohio v. Edward Balmert, Case No. 2024-0669
Ninth District Court of Appeals (Lorain County)
ISSUES:
- Does operating a vehicle while under the influence (OVI) of a controlled substance metabolite establish the “proximate cause” required to convict a driver of aggravated vehicular assault?
- Can a court use evidence that supported an OVI charge alleging actual impairment – of which the driver was found not guilty – to find that a different OVI offense, based on drug metabolite levels, “proximately caused” serious physical harm?
BACKGROUND:
On June 9, 2020, a traffic signal stopped working in Lorain County at the intersection of Middle Ridge Road and ramps on and off of State Route 2. Law enforcement officers directed traffic at the intersection. In the late afternoon, three Ohio State Highway Patrol troopers were dispatched to relieve them.
Once in place, one state trooper waved six vehicles from an off-ramp onto Middle Ridge Road. The trooper saw a “straggler” on the ramp, a white Kia Sportage, and alerted Trooper Cynthia Gehlmann. She instructed the trooper to let the vehicle through.
As Edward Balmert, the driver of the Sportage, turned left onto Middle Ridge, he struck Gehlmann with the driver’s side of the vehicle. She fell to the ground, and Balmert stopped and got out of his vehicle. Gehlmann was transported to a hospital and suffered serious injuries to her head and one arm.
Balmert cooperated with law enforcement at the scene and said he had taken “hemp” that morning. He voluntarily gave a urine sample. He submitted to field sobriety tests, which showed indications of impairment. Tremors in his eyes and body were also observed. Balmert was arrested and taken into custody.
The sergeant who conducted the field tests requested another evaluation to discern whether Balmert was under the influence of cannabis or the signs of impairment were due to medical conditions. Balmert had reported he suffered from rheumatoid arthritis, vertigo, and a perforated eardrum. The law enforcement officer who conducted the additional tests concluded Balmert was under the influence of cannabis.
The crime lab analysis of Balmert’s urine sample found 316 nanograms of THC metabolites per milliliter. The limit in state law is 35 nanograms per milliliter.
Driver Faces Charges, Including Aggravated Vehicular Assault
In October 2020, a grand jury indicted Balmert for aggravated vehicular assault, vehicular assault based on recklessness, operating a vehicle while under the influence (OVI) of drugs, and operating a vehicle while under the influence of a marijuana metabolite. In July 2022, Balmert waived his right to a jury trial and the case was tried before the judge.
At trial, Balmert testified that along with vertigo and ringing in his ears, he had been suffering from severe rheumatoid arthritis for more than 20 years. The prescription medication for it weakened his immune system, causing a hole in his lung and other health issues. He said he stopped taking the medication because of the various side effects. He gave up his commercial driver’s license because of the health conditions. Smoking hemp and consuming hemp oil worked best at relieving his pain and symptoms, he explained. He said he didn’t smoke to get high, noting that the products can be purchased over the counter because of the low levels of THC in them. THC is the psychoactive ingredient in marijuana.
An expert from the crime lab testified that a CBD product containing no THC wouldn’t produce the THC metabolite found in Balmert’s urine. The judge found Balmert guilty of count 1, aggravated vehicular assault, and count 4, OVI due to a controlled substance metabolite. Balmert was found not guilty of the other two offenses.
He was sentenced to the mandatory minimum of two years in prison. Balmert appealed to the Ninth District Court of Appeals. His sentence was put on hold during his appeal. In March 2024, the Ninth District upheld the convictions, but returned the case to the trial court to address a sentencing issue.
In May 2024, Balmert appealed to the Supreme Court of Ohio, which accepted the case. He also began serving his prison term.
Aggravated Vehicular Assault Based on OVI
The General Assembly has enacted laws prohibiting certain driving behaviors that increase the risk of harm to others. One of those driving behaviors is OVI – driving under the influence of alcohol or drugs.
R.C. 2903.08 creates the offense of aggravated vehicular assault. Aggravated vehicular assault can be based on an OVI offense. According to the statute, “No person, while operating or participating in the operation of a motor vehicle … shall cause serious physical harm to another person …as the proximate result of committing a violation of” the OVI laws. Balmert’s OVI conviction was based on the amount of marijuana metabolites found in his urine.
Driver Argues Drug Metabolites Don’t Prove Impairment
Balmert focuses on the “proximate result” language in the statute. It requires the state to prove that serious physical harm caused by a driver was the “proximate result” of the driver’s impairment. The “proximate result” requirement is also referred to as “proximate cause.” Balmert contends that the proper standard for proving the “proximate result” connection is explained in the Sixth District Court of Appeals decisions in Strother v. Hutchinson (1981) and State v. Moore (2019). Applying the standard to this case depends on two factors:
- Whether the state trooper’s injuries were a natural and probable consequence of Balmert driving with a prohibited amount of marijuana metabolites in his urine.
- Whether he should have foreseen that injuries would result from driving with that quantity of metabolites in his system.
Balmert contends that the prosecutor presented evidence of neither. Balmert states that metabolites are what remains in the body after the THC breaks down. The metabolite in his urine was 11-carboxy-THC, which isn’t psychoactive and has no effect on the nervous system, he maintains. The prosecutor failed to prove how metabolites affected his ability, or affect anyone’s ability, to drive safely, Balmert argues.
He also argues there was no evidence presented that he could have foreseen that driving with marijuana metabolites in his system would result in serious physical harm to someone. Even if he didn’t have the prohibited amount of metabolites in his system, Balmert contends that the accident harming the state trooper still would have happened, given other factors such as his medical issues.
He notes that the evidence convinced the trial judge there was reasonable doubt that he was impaired. The judge acquitted him of the OVI charge that depended on proving actual impairment. However, in Balmert’s view, the trial court then improperly concluded that it had to convict him of aggravated vehicular assault because he was found guilty of the metabolite OVI offense, based on the levels in his urine. Balmert contends that the trial court failed to analyze whether proximate result was established.
The Ninth District, in turn, improperly used evidence related to the OVI charge that he was acquitted on to uphold the aggravated vehicular assault conviction, Balmert argues.
State Responds That Driver’s Metabolite Level Was Above Legal Limit
The Lorain County Prosecutor’s Office notes that Ohio appellate courts have used differing approaches to analyze “proximate result” language in criminal laws. The prosecutor and Balmert agree that guidance from the Court is needed to define a clear standard for Ohio courts in these types of cases.
The prosecutor’s brief contends that the correct standard is whether serious physical harm “was a natural and foreseeable consequence within the scope of risk created by the defendant’s conduct.” The focus is on the foreseeability factor, the prosecutor argues, citing the Court’s decision in State v. Crawford (2022). The Court explained in Crawford that foreseeable harm is what matters for determining proximate cause.
The prosecutor notes that Balmert’s OVI conviction based on a prohibited amount of marijuana metabolites is a “per se” OVI offense – which simply defines the point at which the legislature has determined a driver cannot drive without posing a substantial danger to the driver and to others. Balmert’s metabolite level was nearly 10 times the legal limit. Driving a vehicle with an amount of metabolites above the state limit makes a person unsafe to drive, yet Balmert took that risk, the prosecutor maintains. The prosecutor argues the likelihood of a vehicular accident was foreseeable by Balmert given his marijuana use. The resulting injuries to the state trooper “were a natural and foreseeable consequence within the scope of risk he created by driving a vehicle at the statutorily prohibited level of marijuana metabolites,” the state’s brief contends.
The prosecutor rejects the standard in Moore. The prosecutor states that the Sixth District in Moore failed to analyze whether the resulting harm was foreseeable. The court also ruled that the state must present evidence proving a driver was impaired, the prosecutor notes. That standard from Moore goes far beyond what is necessary to prove aggravated vehicular assault – which only requires proving the harm was the proximate result of the underlying OVI offense, the prosecutor argues.
Lawyer Groups, Attorney General Submit Additional Briefs
Amicus curiae briefs supporting Balmert’s positions were submitted by the DUI Defense Lawyers Association and the Ohio Association of Criminal Defense Lawyers. The criminal defense association has asked the Court to participate in oral argument. The association would share time with Balmert.
– Kathleen Maloney
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Edward Balmert: Stephen Hanudel, sph812@gmail.com
Representing the State of Ohio from the Lorain County Prosecutor’s Office: Mark Koza, mark.koza@lcprosecutor.org
Representing the Ohio Association of Criminal Defense Lawyers: Blaise Katter, blaisekatterlaw@gmail.com
Did Police Search of Social Media App Require Warrant?
State of Ohio v. Mamadou Diaw, Case No. 2024-1083
Tenth District Court of Appeals (Franklin County)
ISSUES:
- Must a police officer obtain a search warrant to request that a social media provider turn over the GPS location of a subscriber suspected of using an app to commit a crime?
- Do social media users have a reasonable expectation of privacy in the locations where they previously used a social media app?
OVERVIEW:
The U.S. Supreme Court has ruled, in general, that when a person provides information to a private company, such as a telephone company or a bank, the person has no reasonable expectation of the privacy of the information. When law enforcement seeks those records from these “third parties ,” a person’s rights under the Fourth Amendment to the U.S. Constitution are not violated when records are obtained without a search warrant. The Fourth Amendment protects against unreasonable searches.
In 2018, the U.S. Supreme Court ruled in Carpenter v. United States that information provided to cellphone companies should be treated differently. In Carpenter, the high court noted that a user’s location data is generated by a cellphone once it is powered up. The Carpenter case was about using cell tower location data, but the court also noted that phones produce more precise GPS location data when a person uses some phone features. In Carpenter, the court found that a search of cell tower data to track a suspect’s whereabouts for more than a week required law enforcement to obtain a search warrant.
Since the Carpenter decision, lower courts across the nation have reached various conclusions on whether searches of cellphone data that used less than a week of tower location data required a warrant. In this case, State v. Diaw, the Tenth District Court of Appeals wrote that courts are struggling to apply Carpenter because it failed to set out a clear test as to which information phone users provide to phone companies and information provided to social media apps is protected by the Fourth Amendment and requires a search warrant to reveal.
BACKGROUND:
In 2020, Kareem Wafa found a used MacBook laptop on sale on the social media app Letgo. He arranged to meet the seller, listed as “John Malick,” at a Kroger parking lot in Groveport, Ohio. Wafa was to exchange an iPhone and $350 in cash for the laptop. He encountered two men at the lot, one later identified as Mamadou Diaw. Diaw took the money and phone from Wafa. He began to hand the laptop to Wafa but then pulled it away. Diaw began punching Wafa, and then Diaw and the other man drove away.
Groveport police detective Michael Sturgill investigated the incident. Wafa described the man who hit him and stated the men drove away in a red Honda Accord. He also provided four digits of the license plate and the phone number listed in Letgo for the person who had arranged to sell the laptop.
Sturgill first attempted to use the Ohio Law Enforcement Gateway (OHLEG) to locate the Honda using the four digits from the license plate but could not find a match. A Google search of the phone number revealed the cell carrier was Boost Mobile, which used Sprint cell towers to communicate.
Detective Probes Social Media Companies for Information
Sturgill sent an investigative subpoena, not a search warrant, to Letgo requesting “any and all records” associated with the name John Malick and the attempted sale of the MacBook in the Columbus area posted over a three-day time period in February 2020. Letgo provided a Gmail address and a single latitude and longitude data point. GPS technology generated the latitude and longitude point, which matched a McDonald’s restaurant in Columbus. Sturgill didn’t know the significance of the data point based on what was provided but believed it was where the user last used the Letgo app.
Sturgill sent a search warrant to Sprint seeking information associated with the John Malick phone number. Sturgill stated that Sprint’s policy required a search warrant. Sprint indicated the subscriber, named John Malick, had a Colorado address. Sturgill concluded that a fake name and address were used to open the Letgo account. With the Gmail address provided by Letgo, Sturgill sent a subpoena to Google and found the email address used to open the Letgo account was Diaw’s email. He searched for Diaw in OHLEG and found a driver’s license photo of a man who matched Diaw’s description. Wafa identified Diaw from an array of photos Sturgill showed him.
The address on Diaw’s driver’s license was an apartment in Columbus. That apartment was directly behind the McDonald’s located with the GPS information from Letgo. Sturgill went to the apartment and saw a Honda matching Wafa’s description. Using a broader search on OHLEG, Sturgill found a Honda linked to Diaw.
Diaw was indicted in January 2021 for aggravated robbery and two counts of robbery.
Suspect Seeks To Dismiss Case
After his indictment, Diaw sought to have the Franklin County Common Pleas Court dismiss the case or suppress the evidence used to indict him. He claimed the police obtained information using subpoenas rather than search warrants, which violated his rights under the Fourth Amendment. The trial court didn’t dismiss the case but agreed to suppress the evidence gained from investigating his online accounts using subpoenas.
The Franklin County Prosecutor’s Office appealed the decision to the Tenth District Court of Appeals. The Tenth District reversed the decision, finding that while the officer was wrong to use a broadly worded subpoena to obtain information from Letgo, the trial court incorrectly suppressed the evidence.
Diaw appealed the Tenth District’s decision to the Supreme Court of Ohio, which agreed to hear the case.
Location Data Search Requires Warrant, Suspect Argues
Diaw argues that a key point made by the U.S. Supreme Court in Carpenter is that “location information is not truly shared” by a cellphone user. He notes the decision mentions that GPS data is far more precise than cell tower data and can reveal much about a person’s movements. He maintains that law enforcement must obtain a warrant to request that information from a social media platform.
Diaw considers the Tenth District to be wrong about data collection. The Tenth District noted that a cellphone user doesn’t voluntarily provide cell tower data because the device provides location information without the user taking any action other than turning it on. However, the Tenth District wrote that location data is generated from an app when the person chooses to use the app. Unless users set their app to not reveal location data, they are voluntarily revealing their locations, the Tenth District ruled. Diaw disagrees with this finding.
Diaw maintains the Carpenter decision is broader and that the U.S. Supreme Court stated any activity on a phone generates location data automatically, including “checking for news, weather, or social media.” Because social media is mentioned, it is a private activity, he asserts. Diaw argues that when using the Letgo app on his phone, he wasn’t voluntarily disclosing his location; rather, the phone automatically generated GPS information. Any interpretation allowing a search for a GPS location from an app without a warrant contradicts the Carpenter decision, he argues. The government can’t force a third party to divulge highly revealing digital information such as GPS coordinates without a warrant, he maintains. The detective’s request for “any and all records” from Letgo constituted an unreasonable search, and the information from the search cannot be used at his trial, he concludes.
Data Accessible Without Warrant, Prosecutor Asserts
A single historical data point from an app is far different than what the U.S. Supreme Court has said requires a warrant, the prosecutor argues. In Carpenter, the court was concerned about the warrantless collection of more than 12,000 data points over the course of time and how that information revealed the “whole” of a person’s movements, the prosecutor notes. A single data point, such as in this case, doesn’t reveal anything about a person’s movements at a particular time. It is also different than when law enforcement requests a cellphone company to “ping” a phone in real-time, trying to locate a suspect’s whereabouts by finding a cell tower location, the prosecutor explains.
The information provided by Letgo didn’t state who logged into the account or the significance of the data point, and it was only the detective’s speculation that the data referred to the last time Diaw logged into Letgo, the prosecutor argues. Revealing that a person visited a fast-food restaurant doesn’t provide an intimate window into a person’s life, which was the concern in the Carpenter case, the prosecutor maintains. The fact that it was a GPS location might make it more accurate than a cell tower, but the prosecutor argues there is no expectation of privacy when the location is a public place. The GPS data point was no more an invasion of privacy than if Diaw was seen on an outdoor security camera showing him exiting his apartment, the prosecutor states. The prosecutor also notes the detective didn’t learn of Diaw’s address from the GPS data but found the information when conducting a broader search of the OHLEG database and finding his driver’s license. The limited nature of the GPS information doesn’t demonstrate Diaw had a reasonable expectation that the information would be private, and it didn’t require a search warrant to obtain, the prosecutor concludes.
The prosecutor also argues the U.S. Supreme Court might see cellphone use as “indispensable to participation in modern society,” but that isn’t the same for using an online marketplace app like Letgo. Diaw created and used a Letgo account to arrange a crime and gave information about the sale to Letgo, the prosecutor notes. Diaw voluntarily gave this information to a third party, Letgo, and law enforcement had a right to request that information without a warrant, the prosecutor concludes.
Friend-of-Court Briefs Submitted
An amicus curiae brief supporting the Franklin County prosecutor’s position was submitted by the Ohio Attorney General’s Office. The attorney general was also granted the right to participate in the oral argument and will share time with the prosecutor. The Ohio Prosecuting Attorneys Association also filed an amicus brief supporting the prosecutor.
– Dan Trevas
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Mamadou Diaw: Adam Burke, burke142@gmail.com
Representing the State of Ohio from the Franklin County Prosecutor’s Office: Seth Gilbert, sgilbert@franklincountyohio.gov
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