State v. Billingsley, 2020 Ohio 2673

Appellant Eric Billingsley was charged with two counts of first‑degree misdemeanor domestic violence for incidents on Feb. 19 and Feb. 25, 2019 involving his live‑in girlfriend, Samantha Puckett.
Puckett testified at a bench trial that they had lived together since August 2018, shared a bedroom/bed, and that Billingsley punched her (causing a bruised/swollen eye, chipped tooth, concussion) and later grabbed/choked her; photographs of injuries were admitted.
Puckett also testified Billingsley took her phone and had access to her bank account; she delayed calling police because her belongings remained at the shared residence.
The trial court found Puckett credible, denied Billingsley’s Crim.R. 29 motion, and convicted him of both domestic‑violence counts; sentence was consecutive 180‑day terms with most time suspended and two years community control.
On appeal Billingsley argued (1) insufficiency of the evidence (Crim.R. 29) and (2) that his convictions were against the manifest weight of the evidence, largely asserting Puckett was merely a roommate, not a “family or household member.” The appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence / Crim.R. 29	State: Puckett’s testimony + photographs proved elements of R.C. 2919.25(A) beyond a reasonable doubt	Billingsley: Evidence was insufficient to prove domestic violence	Affirmed — viewed in prosecution’s favor, evidence sufficient to support convictions
Manifest weight of the evidence	State: Trial court reasonably found Puckett credible; physical evidence corroborated her testimony	Billingsley: Convictions against manifest weight; testimony unreliable and inconsistent	Affirmed — appellate court declined to reweigh credibility; no miscarriage of justice
Victim status as “family or household member” (cohabitation)	State: Puckett lived as a spouse; they cohabited, shared bed, commingled possessions, and Billingsley had access to her account	Billingsley: Relationship was platonic/roommate only; state failed to prove cohabitation/consortium	Affirmed — court found cohabitation established under Williams factors; Puckett qualified as household member

State v. Thompkins, 78 Ohio St.3d 380 (standard for sufficiency vs. weight review)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency standard: evidence viewed in light most favorable to prosecution)
State v. Williams, 79 Ohio St.3d 459 (defining cohabitation elements: shared familial/financial responsibilities and consortium)