State v. Chafin, 2019 Ohio 5306

On June 10, 2018, 15‑year‑old L.L. accepted a ride from a Jimmy John’s delivery driver, Jason Chafin, after leaving work; Chafin told her he needed to make a delivery first.
During the drive in a Dominion Homes subdivision, Chafin drove opposite the route L.L. expected, made verbal advances, and grasped L.L.’s hand firmly; L.L. pulled away and jumped from the moving car, sustaining scratches and fear.
Neighbors and L.L.’s father reported the incident to police; witnesses and Jimmy John’s employees corroborated that Chafin was the on‑duty driver and that his red Honda displayed Jimmy John’s items.
Police located Chafin, his red Honda, and photographed L.L.’s injuries; Chafin denied that he picked anyone up and made statements minimizing culpability.
The trial court convicted Chafin of Attempted Abduction (R.C. 2923.02(A), attempted under R.C. 2923.02) after a bench trial and sentenced him to five years’ community control with 60 days local jail.
Chafin appealed, arguing insufficient evidence to prove force or restraint; the appellate court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support attempted abduction (force or threat; substantial step)	State: L.L.’s age, vulnerability, Chafin’s verbal/physical advances, driving opposite the requested route, and L.L.’s jump from a moving car constitute a substantial step and objectively reasonable fear.	Chafin: No evidence he exerted force or threatened L.L.; she jumped voluntarily and there is no proof he restrained her or intended abduction.	Affirmed: Viewed in prosecution’s favor, evidence (acts, statements, circumstances) permitted a reasonable factfinder to find a substantial step toward abduction and objectively reasonable fear.

State v. Woods, 48 Ohio St.2d 127 (Ohio 1976) (establishes "substantial step" and corroboration requirement for attempt)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for appellate sufficiency review)
State v. Walker, 150 Ohio St.3d 409 (Ohio 2016) (sufficiency review is a question of law)
State v. Murphy, 91 Ohio St.3d 516 (Ohio 2001) (evidence, if believed, must convince the average mind)
State v. Group, 98 Ohio St.3d 248 (Ohio 2002) (substantial‑step determination depends on facts and circumstances)
State v. Garner, 74 Ohio St.3d 49 (Ohio 1995) (intent may be inferred from acts and surrounding circumstances)
State v. Davis, 6 Ohio St.3d 91 (Ohio 1983) (force element satisfied where victim’s fear would reasonably induce compliance)
State v. Habtemariam, 103 Ohio App.3d 425 (Ohio Ct. App. 1995) (force test is objective and relies on totality of circumstances)
State v. Bush, 119 Ohio App.3d 146 (Ohio Ct. App. 1997) (victim’s fear must be objectively reasonable)
Alleyne v. United States, 133 S. Ct. 2151 (U.S. 2013) (constitutional requirement that elements be proved beyond a reasonable doubt)