State v. Campbell, 2017 Ohio 5665

Jaylen Campbell was charged with first-degree misdemeanor domestic violence (R.C. 2919.25(A)) for an alleged October 5, 2016 assault on his girlfriend, Jovelie Nelson.
A 911 caller (Laquitha Robinson) reported seeing a male stomp a female and drag her into an upstairs apartment; Robinson could not positively identify the participants.
Officers Boss and Fried responded, located Campbell and Nelson in the upstairs apartment, and recorded interactions on bodycam audio; Nelson denied being assaulted but admitted an argument and a knee injury.
At a November 28, 2016 bench trial the State called Robinson, Nelson, and the two officers; Campbell did not testify after a Crim.R. 29 motion was denied.
The trial court found Campbell guilty and sentenced him to 180 days (150 suspended) and two years' probation.
On appeal Campbell raised (1) that the conviction was against the weight of the evidence and (2) that the trial court improperly discouraged him from testifying, violating his right to testify; the appellate court reversed and remanded for a new trial on the second issue.

Issue	State's Argument	Campbell's Argument	Held
Whether the conviction was against the weight of the evidence	Evidence (911 report, officers on scene, Nelson and Campbell found in apartment, Nelson admitted argument/injury) supports conviction	Evidence was weak: no positive ID by witness, no visible injury, victim denied assault	Overruled — appellate court found evidence did not "weigh heavily" against conviction and was sufficient for bench to infer assault occurred
Whether the trial court improperly advised and thereby discouraged the defendant from testifying, violating his right to testify	Court's admonition was permissible; judges need not always conduct an inquiry into defendant’s decision to testify	The court’s admonition materially changed defendant’s decision to testify and interfered with his personal right	Sustained — admonition influenced Campbell to waive testimony; conviction reversed and case remanded for new trial

State v. Thompkins, 78 Ohio St.3d 380 (weight-of-evidence standard and "thirteenth juror" role)
State v. DeHass, 10 Ohio St.2d 230 (credibility and weight determinations belong to the trier of fact)
State v. Bey, 85 Ohio St.3d 487 (defendant’s right to testify is fundamental; Ohio courts not required to interrogate defendant about decision to testify)
State v. Hunter, 131 Ohio St.3d 67 (high threshold for overturning convictions on manifest weight grounds)
Rock v. Arkansas, 483 U.S. 44 (defendant’s right to testify is a fundamental constitutional right)
Brooks v. Tennessee, 406 U.S. 605 (strategic decisions about testimony implicate constitutional concerns)