Brooklyn v. Woods, 2016 Ohio 1223

William Woods was convicted after a bench trial in Parma Municipal Court of petty theft for paying $17.96 for a TV wall mount priced $99.96 after Walmart asset-protection employees testified he switched UPC stickers with a cheaper accessory.
Asset-protection witnesses (Foster and Cruz) testified they observed Woods place both items in his cart, follow him, saw him change stickers in a grocery aisle, confirmed the underpayment at checkout, and said Woods admitted switching tags.
The store surveillance system did not capture the sticker-switching due to fixed camera angles; a clip showing Woods in the electronics area was admitted as a joint exhibit but was not played live because of technical problems.
Defense counsel did not present witnesses, sought a brief recess for demonstrative evidence from Woods’s car (denied), and repeatedly argued that the video and inconsistencies undermined the witnesses’ credibility.
The trial court found Woods guilty, imposed fines and jail time; Woods appealed raising six assignments of error (right to counsel/presence, ineffective assistance, insufficiency/manifest weight, denial of recess/due process, denial of public trial/confrontation).

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Court viewing surveillance outside counsel/defendant presence	City: reviewing an admitted exhibit for deliberation is permissible and not a critical stage	Woods: court violated Sixth Amendment, confrontation/right to be present, and public trial by viewing video off the record/outside counsel	Affirmed — no constitutional violation where parties agreed exhibit was "heard and submitted," defendant was present at critical stages, and tape remained a public exhibit
2. Ineffective assistance of counsel	City: counsel objected to undisclosed items, used cross-examination, and argued video issues; performance was within professional range	Woods: counsel failed to exclude undisclosed receipt/admission, failed to secure demonstrative evidence, and failed to use video effectively	Affirmed — Strickland not met; objections and arguments made, no prejudice shown
3. Sufficiency of evidence	City: testimony and alleged admission established deception element of theft beyond reasonable doubt	Woods: conviction rests on inference/speculation from underpayment and limited video	Affirmed — testimony and admission sufficed; rational trier of fact could find guilt
4. Manifest weight of evidence	City: trier of fact properly credited witnesses despite minor inconsistencies	Woods: witness inconsistencies and equivocal video make verdict against weight	Affirmed — not an exceptional case; credibility determinations for factfinder, video inconclusive

State v. Schleiger, 21 N.E.3d 1033 (Ohio 2014) (right to counsel at critical stages)
United States v. Wade, 388 U.S. 218 (1967) (right to counsel beyond trial at critical, adversarial stages)
Snyder v. Massachusetts, 291 U.S. 97 (1934) (defendant’s presence required to the extent absence thwarts a fair hearing)
State v. Drummond, 854 N.E.2d 1038 (Ohio 2006) (public-trial right and admission of exhibits as public record)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (sufficiency and manifest-weight standards)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)