State v. Chambers, 2014 Ohio 390

Chambers was convicted of felonious assault and acquitted of kidnapping after a bench trial, in Cuyahoga County Case No. CR-568780.
The victim, Kenneth Straka, was Chambers’ 60-year-old boyfriend who depended on Straka’s Social Security income for support.
On the night of the incident, both men were heavily intoxicated; Straka testified Chambers punched him repeatedly and choked him, causing serious injuries.
Straka was treated at a hospital for a broken rib, a fractured left eye area, facial injuries, a concussion, and required pain management; he later obtained a restraining order.
Chambers testified that he did not recall the events or the assault, claimed Straka groped him, and admitted to punching Straka only once or twice.
The trial court found Chambers guilty of felonious assault and sentenced him to two years in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for serious physical harm	Chambers argues Straka’s injuries were not serious physical harm.	State asserts the injuries constituted serious physical harm under RC 2903.11(A)(1).	Sufficient evidence supports serious physical harm.
Admissibility of prior bad acts testimony	State contends prior conviction testimony is admissible under Evid.R. 404(B) and 609/D.	Chambers argues the evidence was inadmissible under Evid.R. 404(B) and 609, and that he did not open the door.	Admission of the 1999 attempted felonious assault conviction was improper; errors were harmless.
Effective assistance of counsel (trial strategy and cross-examination)	Chambers alleges counsel failed to zealously cross-examine and present his theory.	Chambers claims counsel’s performance was deficient and prejudicial.	No reversible ineffective-assistance error; trial counsel reasonably represented Chambers.
Failure to object to admission of prior acts	Chambers contends trial counsel should have objected to the prior conviction evidence.	Counsel allegedly failed to object to inadmissible prior acts.	No reversible error; admission deemed harmless given overwhelming evidence of guilt.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for sufficiency of the evidence; review for rational juror may find elements proven)