State v. Agnew, 2024 Ohio 295

William T. Agnew was convicted of domestic violence following a bench trial in Butler County Area I Court, Ohio.
The charge arose from an altercation in April 2021, where Agnew punched his half-brother, Nathaniel, at a shared residence.
Testimony and video evidence indicated Agnew initiated physical aggression without provocation, while Nathaniel did not act aggressively or attack Agnew.
Agnew admitted striking Nathaniel but argued both were engaged in "mutual combat" and claimed he acted in self-defense.
Agnew appealed, arguing (1) insufficient evidence that he and Nathaniel resided together as required by statute for domestic violence, and (2) that he did not intend to injure Nathaniel and acted in self-defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence of co-residency	Agnew and Nathaniel resided together, meeting statutory criteria	State failed to show they were residing together or had resided together	There was sufficient evidence of joint residency
Intent to injure/required mens rea	"Knowingly" causing harm suffices; intent not required	Specific intent to injure is required; lacked intent	"Knowingly" is the required mens rea, not intent
Sufficiency of evidence for domestic violence	All elements, including residency and knowing harm, were proven	Insufficient evidence to prove statutory elements	Sufficient evidence supported the conviction
Self-defense	No evidence Agnew acted in self-defense; witnesses and video contradicted	Acted in self-defense due to perceived threat	Self-defense not supported; court not required to analyze sua sponte

State v. Thompkins, 78 Ohio St.3d 380 (standard for reviewing sufficiency of the evidence)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency of evidence review standard)
State v. Stover, 2017-Ohio-291 (definition of "knowingly" as mens rea for domestic violence offense)
State v. Dyer, 2023-Ohio-544 (specific intent to harm not required under domestic violence statute)