State v. Campbell, 2016 Ohio 598

Defendant Gwendolyn Campbell was observed on store surveillance taking items from a Shell station and placing them in her purse; the manager confronted her.
An on-record struggle occurred during which the manager retrieved a beer from her purse; Campbell then produced a box cutter and allegedly threatened to kill the manager.
Campbell left the store with additional items without paying; police arrested her shortly thereafter and recovered a box cutter nearby and candy bars identified as store property in her purse.
Campbell claimed she had purchased the items elsewhere and that she pulled the box cutter in self-defense because she feared the manager.
A jury convicted Campbell of second-degree felony robbery (R.C. 2911.02(A)(2)) for committing theft and threatening physical harm; she was sentenced to five years imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient and verdict against manifest weight for robbery (theft plus threatened harm)	State: Surveillance, victim testimony, admissions, and recovered items prove purposeful theft and threat beyond a reasonable doubt	Campbell: She was justified or acting in self-defense; may have intended to pay or was prevented from paying	Court: Evidence sufficient; conviction not against manifest weight — jury reasonably found purposeful theft and threat

State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (weight-of-the-evidence standard and distinction between sufficiency and manifest weight)
State v. Tolliver, 19 N.E.3d 870 (Ohio 2014) (mens rea for robbery may be satisfied by culpable mental state of theft offense)
State v. Martin, 20 Ohio App.3d 172 (1983) (test for determining whether a conviction is against the manifest weight of the evidence)