Fairfield v. Eubanks, 2014 Ohio 3781

Eubanks was charged with leaving the scene after an accident in Fairfield Municipal Code § 335.13 following an incident at Memories Bar.
Robinson testified Eubanks clipped his knee and left the scene; he claimed he told her to stop.
Long testified that Robinson screamed that Eubanks “just tried to hit me” but did not see contact.
Eubanks testified she left quickly, felt no impact, and did not know of the accident until later.
The trial court found Eubanks guilty; on appeal, the issue is whether knowledge of the accident was proven.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence established knowledge of the accident.	Eubanks argues she lacked knowledge at the time she left.	City asserts knowledge is not required to prove leaving the scene.	Knowledge not proven; conviction vacated.
Whether the conviction is supported by sufficient evidence.	Eubanks contends no proof of knowledge and contact.	City argues substantial evidence supports knowledge and leaving the scene.	Convinction for leaving the scene vacated due to insufficient evidence.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (sufficiency review standard for criminal convictions)
State v. Jenks, 61 Ohio St.3d 259 (1991) (juror-instruction and review framework (bench/jury))
State v. Neely, 2005-Ohio-7045 (Ohio App. Dist.) (knowledge element in failure-to-stop cases)
State v. Gallagher, 2 Ohio App.3d 414 (1981) (knowledge requirement for accident-related offenses)
State v. Blake, 2012-Ohio-3124 (12th Dist. Butler) (sufficiency preservation without Crim.R. 29 objections)
State v. Cooper, 2011-Ohio-1630 (12th Dist. Butler) (weight-of-the-evidence and review standard in bench trials)