State v. Lortz

In State v. Lortz, Summit App. No. 23762, 2008 Ohio 3108, the Ninth District adopted an abuse of discretion standard when applying the corpus delicti rule to admissibility of a confession. Id. at P11. However, the Court adopted the less deferential standard using the manifest weight of the evidence review because we believe the preponderance of the evidence standard applies to determinations concerning preliminary questions of admissibility under Evid.R. 104(A).