What Is Proper Appellate Standard of Review for Trial Court Ruling that 'Other Acts' Evidence was Admissible?

Must Appeals Court Conduct 'Abuse of Discretion' or 'De Novo' Review?

9th District Court of Appeals (Medina County)

ISSUE: ISSUE: In reviewing a trial court's decision to admit evidence of a criminal defendant's prior wrongful acts under Ohio Evidence Rule 404(B), is a court of appeals required to apply a deferential "abuse of discretion" standard, or should the appellate court conduct its own independent "de novo" analysis of whether the evidence was admissible under the rule?