State v. Celli, 2017 Ohio 2746

Background

Frank Celli was convicted after a jury trial for domestic violence against his pregnant girlfriend, N.H., including a pregnancy specification that triggered a mandatory six-month prison term.
The incident occurred on October 18, 2015, during an escalating physical struggle over belongings; witnesses observed N.H. with a bloody lip, scrapes, and appearing distressed.
N.H. gave a statement to police describing being struck and shoved to the ground, but at trial minimized the incident and suggested she felt pressured to make the earlier statement.
Two eyewitnesses (a best friend and a neighbor) testified to physical contact by Celli that caused N.H. to fall and sustain injuries; police photos corroborated physical injuries.
Celli moved for judgment of acquittal and later argued on appeal: (1) the pregnancy-specification mandatory prison term violates equal protection, (2) insufficient evidence that he acted knowingly, and (3) the verdict is against the manifest weight of the evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Equal protection challenge to mandatory prison term under R.C. 2919.25 pregnancy specification	State: statute treats offenders and victims according to neutral criteria; applies equally to male and female offenders; requires offender knowledge of pregnancy	Celli: enhanced penalty is based on victim pregnancy (a female-only characteristic) and thus discriminates on gender and is unconstitutional	Court: statute does not classify offenders by gender; pregnancy spec requires offender knowledge of pregnancy (not merely victim pregnancy); intermediate scrutiny not triggered; provision constitutional as applied and facially
Sufficiency of evidence — mens rea (knowingly)	State: eyewitnesses, victim statement, photos show injuries and an escalating struggle making injury probable, supporting knowledge element	Celli: contact was mutual scuffle; he reacted to victim’s aggression and lacked the requisite awareness that his conduct would probably cause harm	Court: viewing evidence in light most favorable to prosecution, a rational juror could find Celli acted knowingly because engaging in escalating physical conduct made injury probable; sufficiency upheld
Manifest weight of the evidence	State: testimony, photos, 911 calls, and jail call supported credibility of witnesses and victim’s earlier statement	Celli: witness inconsistencies, alleged pressure on victim, best friend’s alleged bias and credibility issues undermine verdict	Court: jurors entitled to resolve credibility conflicts; differences explained by vantage points/timing; evidence did not weigh heavily for acquittal; verdict not against manifest weight

Key Cases Cited

State v. Williams, 126 Ohio St.3d 65 (2010) (federal and Ohio equal protection clauses construed identically)
Am. Assn. of Univ. Professors, Cent. State Univ. Chapter v. Cent. State Univ., 87 Ohio St.3d 55 (1999) (federal and state equal protection analyzed the same)
Beagle v. Walden, 78 Ohio St.3d 59 (1997) (analysis of disparate impact and classifications)
Califano v. Boles, 443 U.S. 282 (1979) (principle that disparate impact on differently defined classes must be shown before further equal protection analysis)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review — evidence viewed in light most favorable to prosecution)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinction between sufficiency and manifest-weight standards)
State v. Otten, 33 Ohio App.3d 339 (1986) (manifest-weight standard and when reversal is appropriate)
State v. Wenger, 58 Ohio St.2d 336 (1979) (knowledge as mens rea: motive, purpose, and mistake of fact irrelevant to knowledge)
State v. Huff, 145 Ohio App.3d 555 (2001) (knowledge may be inferred from surrounding facts and the act itself)