O.R.C. 2907.06(B) Interpretation
In State v. Economo (1996), 76 Ohio St.3d 56, 1996 Ohio 426, 666 N.E.2d 225, the Supreme Court approved the use of circumstantial evidence to satisfy the extrinsic evidence requirement of R.C. 2907.06(B), holding, at p. 60:
"The corroborating evidence necessary to satisfy R.C. 2907.06(B) need not be independently sufficient to convict the accused, and it need not go to every essential element of the crime charged.
Slight circumstances or evidence which tends to support the victim's testimony is satisfactory.
The corroboration requirement of R.C. 2907.06(B) is a threshold inquiry of legal sufficiency to be determined by the trial judge, not a question of proof, which is the province of the factfinder. See State v. Robinson, 83 Ohio St. at 143, 93 N.E. at 625."
Circumstantial evidence is direct proof of one fact from which the existence of another fact which is in issue reasonably may be inferred.