State v. Bentley, 218 N.E.3d 989

Sept. 10, 2020: Bentley was charged in Painesville Municipal Court with Aggravated Trespass (M1) and Assault (M1).
Bentley initially demanded a jury trial but the court conducted a bench trial without a valid waiver; this Court reversed and remanded for a new trial because the jury right was not waived.
On remand Bentley executed a written jury-waiver; bench trial proceeded. Defense argued double jeopardy as to aggravated trespass because of the earlier acquittal.
At trial the victim, Shauna Adkins, testified Bentley punched her causing significant injuries (medical treatment and photos corroborated). Bentley testified Adkins struck him first and he hit her in self-defense; witnesses conflicted.
Trial court acquitted on aggravated trespass, found Bentley guilty of assault, and sentenced him to 90 days jail plus 90 days electronically monitored house arrest.
Bentley appealed, raising denial of Crim.R. 29 (sufficiency), manifest-weight challenges, and a double-jeopardy claim for the retried aggravated trespass; this Court affirmed the assault conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Denial of Crim.R. 29 (sufficiency)	State: viewed in light most favorable to prosecution, evidence (victim testimony, photos, officer statements) sufficed to prove assault.	Bentley: evidence insufficient; he acted in self-defense.	Motion properly denied; evidence legally sufficient to support assault conviction.
2) Manifest weight of the evidence	State: trier of fact credited victim; evidence supports conviction over self-defense claim.	Bentley: conviction against manifest weight because victim not credible and he was initial aggressor.	Weight of evidence supports conviction; credibility determinations were for the trier of fact.
3) Double jeopardy for retried aggravated trespass	State: remand after reversal for lack of jury waiver negated prior trial court decision; retrial not barred because prior judgment was voidable.	Bentley: retrial after acquittal violated double jeopardy and evidence introduced at retrial tainted assault conviction.	Court found retrial did not require reversal; waiver defect made earlier judgment voidable (not void), and any evidence overlap was admissible or harmless; no reversible error.

State v. Bridgeman, 55 Ohio St.2d 261 (1978) (Crim.R.29 sufficiency standard)
State v. Jenks, 61 Ohio St.3d 259 (1991) (adopting Jackson sufficiency standard)
Jackson v. Virginia, 443 U.S. 307 (1979) (reasonable-doubt sufficiency inquiry)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing sufficiency from manifest weight)
Pratts v. Hurley, 102 Ohio St.3d 81 (2004) (error in exercise of jurisdiction renders judgment voidable, not void)
State v. Coombs, 18 Ohio St.3d 123 (1985) (presumption trial court applied correct law)