State v. Cantrell, 2016 Ohio 7623

Defendant Justan B. Cantrell was convicted after a bench trial of aggravated burglary with a firearm specification and having a weapon while under disability; sentenced to an aggregate six-year prison term.
Victim Chatiya Cranford testified Cantrell entered her apartment at night, pointed a handgun at her, threatened to kill her, and later fired a shot outside. Cranford said the front door was already partly open and that Cantrell pushed it wider to enter.
Neighbor Lillia Arnold testified she saw Cantrell open the screen door and enter carrying a handgun, then come back out and fire a shot; she believed the main door was already open but could not specify how much.
Police corroborated that Cranford reported Burns opened the screen door and Cantrell walked in; officer testified he could not locate a shell casing and recorded differing descriptions of the gun color.
The trial court credited Arnold’s testimony that Cantrell opened the screen door and held that opening a closed, unlocked door constitutes the use of force under R.C. 2911.11(A); it also noted Cranford’s testimony that Cantrell threatened her inside.
On appeal Cantrell challenged legal sufficiency and manifest weight as to the "force, stealth, or deception" element of aggravated burglary; the appellate court affirmed, accepting the trial court’s credibility choice and finding the evidence legally sufficient.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports a finding Cantrell trespassed by "force" under R.C. 2911.11(A)	State: Arnold’s eyewitness testimony that Cantrell opened the screen door and entered is credible and shows use of force.	Cantrell: Victim said door was already open and Burns opened the screen door; evidence does not show defendant used force.	The court held evidence was legally sufficient and not against the manifest weight; opening a closed/unlocked door can be "force."
Whether conviction is against the manifest weight of the evidence	State: Trial court properly weighed witnesses and credited neutral eyewitness (Arnold).	Cantrell: Conflicting testimony (Cranford vs Arnold) undermines verdict; trial court erred in crediting Arnold.	The court held the trial court did not clearly lose its way; credibility determinations were for the trier of fact.
Whether alternative theory of "stealth" needed analysis	State: Not necessary once "force" is established.	Cantrell: Court’s alternative stealth finding unsupported.	The court declined to reach stealth because force was sufficiently proven.
Whether aggravated burglary required completion before Cantrell left apartment	State: Court relied on menacing inside (pointing gun/threats) for burglary.	Cantrell: Suggests offense may not have been completed until after he left (shot fired outside).	Court noted it did not rely on the outside gunshot; menacing inside supported the conviction.

Jenks v. Ohio, 61 Ohio St.3d 259, 574 N.E.2d 492 (Ohio 1991) (standard for reviewing sufficiency of the evidence)
Thompkins v. Ohio, 78 Ohio St.3d 380, 678 N.E.2d 541 (Ohio 1997) (standard for reviewing manifest-weight claims)
State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (Ohio Ct. App. 1983) (weight-of-the-evidence reversal is appropriate only in exceptional cases)