In re Q.W., 2017 Ohio 8311

Minor appellant Q.W. was adjudicated delinquent for two counts of telecommunications harassment (R.C. 2917.21(A)(3)) for threatening text messages and calls that, if by an adult, would be first-degree misdemeanors.
Victim’s daughter had been in a relationship with Q.W.; victim disapproved, and a physical/verbal altercation between victim and her daughter led to the daughter’s arrest.
Over several days the victim received numerous threatening texts and calls from an unfamiliar phone number threatening to kill the victim and damage her property (e.g., throat-slitting, bashing with a brick, burning the house, blowing up the car).
The victim produced screen-captured reproductions of the text messages showing the sender number; she testified that the calls came from the same number and that she recognized the caller’s voice as Q.W’s.
The state offered no phone records, triangulation, or other technical evidence linking the number to Q.W.; the only direct link was the victim’s voice identification.
Juvenile court imposed six months community control; Q.W. appealed, arguing insufficiency of evidence and that the adjudications were against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: Whether evidence linked Q.W. to texts/calls and proved telecommunications harassment	Victim’s testimony and message reproductions (with sender number) suffice to establish that Q.W. made/caused the telecoms and knowingly caused fear of serious harm	Plaintiff (Q.W.) argued there was no evidentiary link tying the phone number or calls to her (no logs, triangulation, or other records)	Court held evidence was sufficient: victim’s identification and message reproductions could support a rational factfinder’s verdict
Manifest weight: Whether the adjudication was against the manifest weight of the evidence	State: Victim’s uncontroverted testimony supports the adjudication	Q.W.: Father’s testimony (providing a different phone number and allegedly checking her phone) undermines credibility of victim and creates reasonable doubt	Court held no manifest miscarriage: victim’s testimony was uncontroverted in material respects and father’s testimony did not create a conflict sufficient to reverse

State v. Leonard, 104 Ohio St.3d 54 (2004) (defines sufficiency review standard as viewing evidence in light most favorable to the prosecution)
State v. Jenks, 61 Ohio St.3d 259 (1991) (explains that sufficiency asks whether admitted evidence, if believed, could convince an average mind of guilt beyond a reasonable doubt)
State v. Roseberry, 197 Ohio App.3d 256 (2011) (reproductions of text messages authenticated via recipient’s testimony)
Bedford Heights v. Tallarico, 25 Ohio St.2d 211 (1971) (voice identification by the conversation partner may suffice if the witness testifies they recognized the defendant’s voice)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (clarifies manifest-weight standard and that new trial is warranted only in exceptional cases)
State v. Martin, 20 Ohio App.3d 172 (1983) (discusses standards for granting a new trial on manifest-weight grounds)