State v. Beamer, 2012 Ohio 2222

May 29, 2011, deputy and EMS responded to an unresponsive Beamer in a hot vehicle; Beamer woke belligerent and refused treatment.
Beamer was charged with aggravated disorderly conduct under R.C. 2917.11(A)(2).
Bench trial held July 20, 2011; Beamer found guilty and fined; judgment entered August 10, 2011.
Beamer appealed alleging insufficient evidence to support conviction.
Appellate court affirmed the Municipal Court, holding evidence supported disorderly conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to convict disorderly conduct	Beamer argues insufficient evidence	Beamer contends words not fighting words	Sufficient evidence; conviction affirmed

State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review)
Jackson v. Virginia, 443 U.S. 307 (1969) (sufficiency standard from constitutional review)
State v. Hoffman, 57 Ohio St.2d 129 (1979) (fighting-words doctrine scope)
State v. Wood, 112 Ohio App.3d 621 (1996) (fighting words vs. general vulgarity)
State v. Thompson, # (2002) (2002) (fighting words paradigm with Chaplinsky reference)
Chaplinsky v. New Hampshire, 315 U.S. 568 (1942) (origin of fighting words concept)
State v. Presley, 81 Ohio App.3d 721 (1992) (context for evaluating language impact)
Kent v. Kelley, 44 Ohio St.2d 43 (1975) (examples of non-fighting vulgarity)
Toledo v. Grince, 48 Ohio App.3d 126 (1989) (examples of non-fighting words)
State v. Lamm, 80 Ohio App.3d 510 (1992) (illustrates vulgarity without fighting words)
Cincinnati v. Karlan, 39 Ohio St.2d 107 (1974) (illustrative fighting-word statements)
Middletown v. Carpenter, 2006-Ohio-3625 () (analysis of offensive language toward police)