State v. Butler, 2012 Ohio 5030

Butler was convicted by jury of Domestic Violence and Disrupting Public Service after a July 12, 2011 incident with his wife Elizabeth.
Elizabeth testified Butler attacked her with a knife, damaged her phone, and prevented emergency calls during the altercation.
Butler admitted breaking the phone but denied using a knife; photographs of injuries and the knife were admitted, though the knife itself was lost.
Butler was charged with three counts: Domestic Violence, Disrupting Public Service, and Felonious Assault; he did not testify.
The jury found Butler guilty of Domestic Violence and Disrupting Public Service, and not guilty of Felonious Assault; Butler appeals asserting five assignments of error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for Domestic Violence	Butler argues evidence insufficient.	Butler contends lack of competent evidence.	Evidence sufficient; rational jury could convict.
Sufficiency of evidence for Disrupting Public Service	State asserts interruption of services by destroying phone.	Butler argues insufficient proof of disrupted service.	Evidence sufficient; destruction of phone and delay in emergency response supported.
Weight of the evidence for Domestic Violence	State contends verdict not against weight of the evidence.	Butler asserts weight favors acquittal.	Not a manifest weight error; jury credibility determinations preserved.
Weight of the evidence for Disrupting Public Service	State relies on substantial interference evidence.	Weight favors defendant.	Not against the weight of the evidence; affirmed.
Ineffective assistance of counsel regarding references to a prior federal conviction	N/A	Trial references to federal conviction were prejudicial; failure to object ineffective.	Assignment rejected; references did not prejudice given other supportive evidence.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard: rational trier of fact could convict)
State v. Carter, 72 Ohio St.3d 545 (1995) (sufficiency review standard)
State v. Jenks, 61 Ohio St.3d 259 (1991) (ultimate test of circumstantial evidence)
Thompkins v. State, 78 Ohio St.3d 380 (1997) (weight of evidence and credibility considerations)
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (1984) (appellate review presumes evidence supporting verdict)
Cross v. Ledford, 161 Ohio St. 469 (1954) (credibility andlege of conflicting testimony)
State v. Woods, 48 Ohio St.2d 127 (1976) (defining substantial step for attempt)
State v. Group, 98 Ohio St.3d 248 (2002) (application of substantial-step and de facto intent)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility and weight of evidence guidance)
State v. Robinson, 124 Ohio St.3d 76 (2009) (damaging telecommunications device under 2909.04(A))