Cleveland v. Watson, 2020 Ohio 3284

Watson (defendant) was charged with misdemeanor domestic violence (R.C. 2919.25(A)) and misdemeanor unlawful restraint (C.C.O. 621.08(a)) after an June 9, 2018 incident at a shared apartment.
Victim M.D. testified Watson grabbed her hair (weave) and swung her, it "hurt," M.D. hid in the bathroom, and Watson and a friend broke the bathroom door and poked M.D. with craft scissors, leaving a small mark.
Witness Glenn Williams and Watson gave a competing version: M.D. was the aggressor, damaged the door, and Watson did not touch M.D.
Trial court found M.D. credible, discredited Williams, admitted photos of door and wall damage, and convicted Watson of both charges; sentenced to jail with probation conditions.
On appeal Watson argued ineffective assistance for counsel’s failure to move for acquittal (Crim.R. 29) and that convictions were against the manifest weight of the evidence.
The court affirmed the domestic-violence conviction (sufficient evidence; not against manifest weight) but reversed/vacated the unlawful-restraint conviction for insufficiency and remanded for entry of judgment reflecting that vacatur.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for domestic violence (and whether counsel ineffective for not moving for acquittal)	City: M.D.’s testimony and photos show physical harm (hair-pulling, pain, and a visible mark); a Crim.R.29 motion would be futile.	Watson: Counsel ineffective for failing to move for acquittal because evidence of physical harm was insufficient (hair-pulling/ minor scratch insufficient).	Held: Evidence sufficient; victim’s testimony alone can sustain conviction; counsel not ineffective on this point.
Sufficiency of evidence for unlawful restraint (and whether counsel ineffective for not moving for acquittal)	City: M.D. was restrained in bathroom and by hair-pulling; her liberty was limited.	Watson: M.D. entered bathroom voluntarily and was not prevented from leaving; no evidence she attempted to escape; hair-pulling did not constitute restraint of liberty.	Held: Insufficient evidence of unlawful restraint (no proof M.D. was prevented from leaving or totally restrained); conviction vacated.
Manifest-weight challenge to domestic-violence conviction	City: Photographs and M.D.’s testimony corroborate and support trial court credibility determinations.	Watson: Lack of corroborating medical evidence and defense testimony undermines M.D.’s account; conviction against weight of evidence.	Held: Not against manifest weight; trial court did not clearly lose its way—photos and testimony supported verdict.

Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance of counsel)
State v. Bradley, 42 Ohio St.3d 136 (1989) (Ohio adoption of Strickland standard)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight standard; appellate court as "thirteenth juror")
State v. Martin, 20 Ohio App.3d 172 (1983) (describes appropriate use of manifest-weight review)