State v. A.N.C, 2018 Ohio 362

On Oct. 6, 2015, a complaint charged 12‑year‑old A.N.C. as a delinquent child for burglary (R.C. 2911.12(B)) of Scott and Marybeth Gray’s home; two other 12‑year‑old girls (K.L.P.W. and V.A.C.) were co‑defendants.
Neighbor Beverly Luncan observed the three girls raise a garage door enough to crawl under and called police; Officer Darcy Workman arrived, heard talking/laughter from the garage, ordered occupants out, and then saw the girls emerge from behind the residence.
A joint adjudication hearing was held Jan. 11, 2016; the magistrate adjudicated A.N.C. delinquent on Jan. 20, 2016; the juvenile court later adopted the adjudication and a dispositional order (community service, costs, 5‑day commitment suspended).
A.N.C. appealed, arguing her adjudication was against the manifest weight of the evidence and insufficient as to three elements: use of force, trespass, and presence (or likelihood of presence) of another person in the habitation.
The court reviewed the record, treating circumstantial evidence as having equal probative value to direct evidence, and reaffirmed earlier rulings as to the co‑defendants in related appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports finding A.N.C. used force, stealth, or deception to trespass	State: Circumstantial evidence (neighbor observed raising garage door; officer heard voices/laughter; girls emerged after being ordered out) proves they forced entry	A.N.C.: No direct eyewitness shows she used force; insufficiency/weight issue	Court: Circumstantial evidence sufficient; adjudication upheld
Whether evidence supports that A.N.C. trespassed into the garage	State: Conduct and timing (voices inside, emergence from behind house) show trespass	A.N.C.: No proof she actually entered the garage	Court: Evidence supports trespass finding
Whether another person was present or likely to be present in the habitation	State: Residence (attached garage) is a permanent dwelling where persons are likely to be present; prior rulings on co‑defendants support this	A.N.C.: No evidence anyone else was present or likely to be present	Court: Record establishes habitation and likelihood of presence; element satisfied
Whether adjudication was against manifest weight / insufficient	State: Credible witnesses and circumstantial proof satisfy both sufficiency and weight standards	A.N.C.: Trial court lost its way; evidence favors acquittal	Court: No miscarriage of justice; adjudication supported by manifest weight and sufficient evidence

State v. Jenks, 61 Ohio St.3d 259 (1991) (sets the standard for sufficiency review in criminal cases)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest‑weight review and explains their different inquiries)