State v. Brown, 2014 Ohio 5702

Brown, store loss-prevention observed suspected shoplifting behaviors without a purse or wallet.
Video footage showed Brown in girls’ department; she concealed items near a rack and appeared to surveil cameras.
Brown fled with a cart; loss-prevention officer Anderson chased and attempted to detain her.
During flight Brown discarded clothes, blocked Anderson’s attempts to contact police, and punched him to prevent communication.
Police apprehended Brown in a field after she shed more clothes; Brown did not testify in her defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for robbery convictions	State argued Brown’s actions during the flight met robbery elements	Brown argued the evidence did not prove immediate infliction of force	No; convictions affirmed for sufficiency
Manifest weight of the evidence	State contended jury credibility supported conviction	Brown argued weight of evidence favored acquittal	No; convictions affirmed as not against the weight of the evidence

State v. Bridgeman, 55 Ohio St.2d 261 (Ohio 1978) (standard for sufficiency review: reasonable minds may differ)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (thirteenth juror; weight of the evidence review)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility of witnesses; jury's assessment given deference)
State v. Thomas, 106 Ohio St.3d 133 (Ohio 2005) (definition of 'flee' and 'immediately' in robbery statute)
State v. Lynch, 2014-Ohio-1775 (Ohio 2014) (appellate review of weight when assessing credibility)