State v. Casey, 2024 Ohio 689

Kevin Casey was charged with fourth-degree misdemeanor domestic violence (R.C. 2919.25(C)) after allegedly pointing a loaded firearm at his sister during an altercation at his home on April 15, 2023.
The incident arose after Casey’s sister visited him to deliver family belongings; during a confrontation, Casey allegedly threatened her and pointed the gun at her in a manner she believed indicated imminent physical harm.
The victim testified Casey’s actions caused her to fear for her life, citing both his conduct during the incident and previous threats.
Casey was convicted by a jury and sentenced to a two-year term of community control, plus a partially stayed jail term.
On appeal, Casey argued the conviction was against the manifest weight of the evidence and unsupported by sufficient evidence, focusing on the credibility and sufficiency of his sister’s testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence to support Casey’s conviction?	Victim’s testimony proved belief in imminent harm	No evidence shows Casey knowingly caused fear or harm	There was sufficient evidence; conviction affirmed
Was the conviction against the manifest weight of the evidence?	Victim’s testimony was credible and detailed	Victim’s testimony should not be fully credited	The conviction was not against the manifest weight

State v. Jenks, 61 Ohio St.3d 259 (sets forth standard for sufficiency of the evidence review)
State v. Thompkins, 78 Ohio St.3d 380 (distinguishes between sufficiency and manifest weight review)
State v. DeHass, 10 Ohio St.2d 230 (jury is primary judge of witness credibility)
Hamilton v. Cameron, 121 Ohio App.3d 445 (victim’s state of mind essential for R.C. 2919.25(C) conviction)
Cincinnati v. Baarlaer, 115 Ohio App.3d 521 (defines "imminence" for domestic violence statute)