State v. Beckwith, 2013 Ohio 492

Beckwith was charged with menacing by stalking, including a furthermore trespass specification targeting Benson at Benson's place of employment.
Benson testified Beckwith followed her on multiple library-related occasions and made unsettling noises toward her, creating a pattern of conduct.
Incidents included asking for a book, asking for help downloading a song, and allegedly filming Benson with a cell phone; security advised Beckwith to stay away.
Beckwith was present near Benson at the library and near The Arcade across the street, with Benson describing her fear and discomfort.
The trial court convicted Beckwith and sentenced him to prison and a fine.
On appeal, the court reversed and remanded, finding insufficiency to prove mental distress and unlawful trespass under the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence legally sufficient for menacing by stalking?	Beckwith contends Benson’s distress was not proven knowingly.	Beckwith argues his conduct did not cause mental distress or imply imminent physical harm.	Yes, insufficient evidence to sustain the conviction.
Was the evidence legally sufficient for the furthermore trespass specification?	Beckwith allegedly trespassed at Benson's workplace while stalking.	Beckwith visited a public library; no trespass after Flak warned him.	No, insufficient evidence Beckwith trespassed at the library while stalking.

State v. Diar, 120 Ohio St.3d 460 (Ohio Sup. Ct. 2008) (sufficiency standard under due process)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio Sup. Ct. 1997) (due process sufficiency review)
State v. Jenks, 61 Ohio St.3d 259 (Ohio Sup. Ct. 1991) (Jackson v. Virginia standard)
McKinley v. Kuhn, 2011-Ohio-134 (4th Dist. 2011) (evidence sufficiency for distress)
Kramer v. Kramer, 2002-Ohio-4383 (3d Dist. 2002) (pattern of harassment and fear)
Cannon, 2011-Ohio-2394 (8th Dist. 2011) (example of sufficiency in stalking context)