Franklin County Criminal Law Casebook

Reproduced with permission from:
Timothy E. Pierce and the Franklin County Public Defender Office

R.C. 2911.31 -- Safecracking.
State v. Perkins (1994), 93 Ohio App. 3d 672 -- The combination to a safe constitutes property for purposes of establishing a theft offense.
State v. Gover (1990), 67 Ohio App. 3d 384 -- "Smackwater Jack's" restaurant used a vault as a private dining area. Inside the vault was a small safe with trinkets on display inside and closed off by a plexiglas cover. Defendant was convicted of safecracking for having broken the cover and removing trinkets. Reversed.
State v. Snowden (1976), 49 Ohio App. 2d 7, 13-14 -- Similar acts evidence relating to theft is immaterial in a prosecution for safecracking.
State v. Carroll (1984), 14 Ohio App. 3d 51 -- The offenses of breaking and entering and safecracking do not merge for purposes of sentencing.
Ohio Attorney General's Opinion No. 84-040 -- The safecracking statute does not apply to the insertion of a stolen credit card into an automatic teller device. Also see State v. Stotridge, Ross County Court of Appeals No. 1982-63 -- Safecracking statute does not apply to prying open a cash register.

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Published by Timothy E. Pierce
Copyright © Franklin County Public Defender and Timothy E. Pierce, 2015
Contents may not be duplicated without express permission.