State v. Boyd, 2020 Ohio 3450

Infant hospitalized May 22, 2016 after grandmother found him with swollen eyes and "gurgitating"; paramedic observed seizure-like/postictal behavior. 911 call and transport to Rainbow Babies and Children’s Hospital followed.
MRI showed bilateral subacute subdural hematomas; treating pediatrician/child-abuse expert opined the bleeds were 7–21 days old and consistent with shaking (nonaccidental trauma).
Appellant (mother) and the father were arrested and jointly indicted: Count 1 (child abuse under R.C. 2919.22(B)(1)) and Count 2 (endangering children by violating duty of care under R.C. 2919.22(A)), each with a "furthermore" clause alleging serious physical harm.
Jury acquitted both on Count 1, found both guilty on Count 2 but not guilty of the "furthermore" clause, resulting in misdemeanor convictions; the court imposed two years community control.
Appellant filed a delayed appeal raising (1) insufficiency of the evidence and (2) manifest-weight challenges; the Eighth District affirmed the conviction, finding the evidence supported a finding that appellant recklessly failed to seek timely medical care.

Issue	State's Argument	Boyd's Argument	Held
Sufficiency of the evidence to sustain R.C. 2919.22(A) conviction	Evidence (medical opinion, timeline, witnesses) shows infant had subacute subdural hematomas and parents recklessly failed to obtain timely care, creating a substantial risk	Conviction rests on status as mother; no proof Boyd caused the injury or acted culpably	Affirmed — evidence, viewed in favor of prosecution, supports conviction for neglect (reckless omission) under R.C. 2919.22(A)
Manifest weight of the evidence	Jury reasonably credited medical and witness testimony tying symptoms and delayed care to the child’s harm	Jury’s acquittal on "furthermore" clause shows inconsistent verdict; verdict may reflect punishing someone without proof	Affirmed — record does not show jury clearly lost its way; conviction not a miscarriage of justice

State v. Jenks, 61 Ohio St.3d 259 (standard for reviewing sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (distinguishes sufficiency from manifest-weight review; explains manifest-weight standard)
State v. O’Brien, 30 Ohio St.3d 122 (child-endangering under R.C. 2919.22(A) requires proof of recklessness)
State v. Kamel, 12 Ohio St.3d 306 (R.C. 2919.22(A) reaches omissions/neglect in failing to protect a child)
State v. Martin, 20 Ohio App.3d 172 (framework for manifest-weight/new-trial analysis)
Cleveland Hts. v. Cohen, 31 N.E.3d 695 (child-endangering conviction may rest on an isolated incident)
State v. Wilson, 41 Ohio St.2d 236 (mootness principle when sentence completed absent collateral disability)