State v. Allsup, 2011 Ohio 405

Allsup was indicted in 2009 on five counts, including complicity to disobey a police order, complicity to felonious assault on a police officer, vehicular vandalism, complicity to vandalism, and obstructing official business.
He was found competent to stand trial after two competency evaluations and underwent a jury trial in February 2010 resulting in guilty verdicts on all counts.
Concurrently, the State sought revocation of Allsup’s prior community control/supervision in a related case; the court held a re-sentencing and revocation hearing in March 2010.
Sentences issued March 9, 2010 included a total term of 11 years 5 months, with counts 1–2 serving consecutive terms and counts 3–5 serving a concurrent term, plus driver’s license suspensions and various cost/tess of fees.
Allsup timely appealed raising sufficiency and manifest weight challenges to counts 1 and 2, and a due-process challenge to the revocation hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence supported acquittal on counts 1–2	Allsup contends motor vehicles aren’t per se deadly weapons and there wasn’t sufficient evidence of complicity.	Allsup argues insufficient evidence that he aided or abetted the underlying offenses.	Sufficiency affirmed; evidence supported aiding and abetting.
Whether the convictions for complicity were against the manifest weight of the evidence	Allsup claims the evidence doesn’t prove he acted with the requisite complicity intent.	Allsup contends the jury misconstrued the facts and weight favors acquittal.	Manifest weight claim rejected; evidence not against the weight of the evidence.
Whether there was due process error at the community-control revocation hearing	Allsup asserts no preliminary probable-cause hearing, limited opportunity to present evidence, and a biased hearing body.	Allsup contends these procedures were violated and prejudiced him.	No plain error; proceedings satisfied due-process requirements given notice,Counsel, and opportunity to be heard.

State v. Bridgeman, 55 Ohio St.2d 261 (Ohio 1978) (sufficiency standard: Bridgeman standard integrated with sufficiency review)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1981) (sufficiency standard for reviewing evidence)
State v. Foster, 3d Dist. No. 13-97-09 (Ohio 1997) (bridging sufficiency standard with appellate review)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility and weight are appellate deference matters)
State v. Miller, 42 Ohio St.2d 102 (Ohio 1975) (due-process-adjacent revocation standards Morrissey/Miller framework)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (weight of the evidence and credibility deferential review)
State v. Ryan, 2007-Ohio-4743 (Ohio) (due-process in probation revocation; fixed notice and hearing rights)