State v. Bloodworth
2017 Ohio 9122
| Ohio Ct. App. | 2017Background
- Phillip Bloodworth, an inmate at Mansfield Correctional Institution, was indicted on two counts of assault on a corrections officer (third-degree felonies) for an incident on June 21, 2015.
- At trial (self-represented with counsel assistance), officers Jamie Vilfer and Joseph Sutton testified they were assaulted after denying Bloodworth an extra brownie in the chow line.
- Officer Sutton testified Bloodworth struck him multiple times in the face; both officers testified Bloodworth later threw a chair that struck them.
- Officers testified they issued repeated commands to stop; Bloodworth ignored them, was OC-sprayed, ran, and was subdued. No hallway video existed; injuries ranged from minor (Vilfer) to facial swelling and bruising (Sutton).
- A prison disciplinary board previously found Bloodworth guilty of assault infractions; that finding was upheld administratively.
- The jury convicted Bloodworth on both counts; the trial court imposed an aggregate 72-month consecutive prison term. Bloodworth appealed, arguing insufficient evidence of knowing physical harm.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was sufficient evidence to support convictions for assault on corrections officers under R.C. 2903.13(A)/(C)(3) | The State: testimony established Bloodworth knowingly caused physical harm by punching and throwing a chair, and ignored orders, satisfying the statute. | Bloodworth: trial testimony lacked proof he acted "knowingly"; incidents could be construed as resistance to handling; no independent witnesses or video. | Affirmed: viewing evidence in favor of the prosecution, a rational juror could find the elements beyond a reasonable doubt. |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review: whether, viewing evidence in light most favorable to the prosecution, any rational trier of fact could find guilt beyond a reasonable doubt)
- Jackson v. Virginia, 443 U.S. 307 (1979) (constitutional sufficiency standard adopted for review)
- State v. Miller, 96 Ohio St.3d 384 (2002) (definition of acting knowingly: aware conduct will probably cause a result)
- Miller v. Paulson, 97 Ohio App.3d 217 (10th Dist. 1994) (definition of "probably" as more likely than not)