State v. Champion, 2021 Ohio 4002

On April 24, 2020, Tyeisha Champion and her cousin used Walmart self-checkout; several items (clothing, sandals, candles, etc.) were not scanned and left the store, totaling about $278.95.
Walmart loss-prevention employee Gracie Stamper monitored self-checkout cameras and a handheld device that displayed scanned items and prices; she observed the women scan few items, place other items into bags, and leave.
An electronic item was scanned with a price tag from $7.98 sandals attached; the electronic item’s true price was $119. Stamper did not see who moved the tag.
Champion testified she had scanned her items, her cousin paid for the cart, and she attempted to reimburse her cousin but could not; video evidence was not introduced at trial.
After a bench trial, the court credited Stamper’s testimony, found Champion guilty of misdemeanor theft under R.C. 2913.02(A)(1), and Champion appealed on sufficiency and manifest-weight grounds.
The appellate court affirmed, holding the evidence was sufficient and the verdict was not against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove theft	State: Stamper’s testimony showed Champion knowingly exerted control over unscanned, unpaid merchandise without consent	Champion: Stamper did not identify specific items Champion took or establish value; Champion said she scanned items	The evidence was sufficient; intent inferred from placing unscanned items in bags and leaving without paying
Manifest weight of the evidence	State: Credible eyewitness testimony supported conviction; trier of fact entitled to credit that testimony	Champion: Her testimony that she scanned items created reasonable doubt and weighs against conviction	No miscarriage of justice; trial court credited prosecution witness and did not clearly lose its way

State v. Jenks, 61 Ohio St.3d 259 (establishes standard for reviewing sufficiency of evidence)
State v. Issa, 93 Ohio St.3d 49 (credibility determinations are for the trier of fact)
Barberton v. Jenney, 126 Ohio St.3d 5 (deference to factfinder on witness credibility)
State v. Thompkins, 78 Ohio St.3d 380 (standard and framework for manifest-weight review)
State v. Martin, 20 Ohio App.3d 172 (manifest-weight reversal reserved for exceptional cases)
State v. Smith, 121 Ohio St.3d 409 (value is not an element of theft but affects punishment)