State v. Campbell, 2017 Ohio 9251

On May 31–June 1, 2016, Jeff “Boo” Simpson and Anthony Campbell picked up Cynthia Kindred after Simpson told her someone she knew was in the hospital; Campbell rode in the car and later accompanied Kindred into a bank.
In the bank Kindred filled a withdrawal slip for $730 and wrote the note “He going to kill,” appearing frightened; the teller signaled to call police and officers responded quickly.
Campbell was arrested at the scene; a recorded police interview captured admissions that Simpson deceived Kindred, that Simpson threatened to beat her for money, and that Campbell accompanied Kindred into the bank at Simpson’s request.
Kindred died later that day of a drug overdose; her death was unrelated to the bank incident.
Campbell was charged with robbery and kidnapping; the court merged counts and the State elected to proceed on kidnapping by complicity (kidnapping to facilitate a felony).
Campbell was convicted; on appeal he argued the evidence was legally insufficient and that the verdict was against the manifest weight of the evidence. The court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Campbell)	Held
Sufficiency: Was there sufficient evidence to prove kidnapping by complicity under R.C. 2905.01(A)(2)?	State: Yes — recorded admissions, teller’s note, teller testimony, photos, and officer testimony support deception, restraint, and purpose to facilitate a felony.	Campbell: No — State failed to prove deception/force removed Kindred or that Campbell restrained her liberty at the bank.	Held: Yes. Viewing evidence in light most favorable to prosecution, a rational trier of fact could find the elements proven beyond a reasonable doubt.
Manifest weight: Did the evidence weigh against the guilty verdict?	State: The jury reasonably credited the recorded interview and circumstantial evidence showing complicity.	Campbell: The evidence does not show Kindred was deceived or that Campbell threatened or physically restrained her; his trial testimony contradicted the interview.	Held: No. The appellate court concluded the jury did not lose its way; the verdict was not against the manifest weight.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency: whether evidence, if believed, could convince a reasonable mind beyond a reasonable doubt)
State v. Johnson, 93 Ohio St.3d 240 (2001) (aiding-and-abetting elements and intent can be inferred from presence and conduct)
State v. Awan, 22 Ohio St.3d 120 (1986) (credibility determinations are for the trier of fact)
State v. Hunter, 131 Ohio St.3d 67 (2011) (appellate reversal on manifest weight is limited to exceptional cases)
State v. Monroe, 105 Ohio St.3d 384 (2005) (restating sufficiency standard)
State v. Smith, 80 Ohio St.3d 89 (1997) (procedural note on Jenks authority)