State v. Craddock
2025 Ohio 2041
Ohio Ct. App.2025Background
- Larissa Craddock was subject to a civil stalking protection order issued in favor of K.J., her daughter’s stepmother, prohibiting contact, harassment, and coming within 500 feet of K.J.
- On February 25, 2024, Craddock went to K.J.’s residence with a police escort to pick up her daughter but engaged in harassing behavior, including making derogatory comments and videotaping K.J.
- Deputy Wessline, present during the encounter, gave clear instructions for Craddock not to engage or communicate with K.J.; Craddock ignored these and continued the conduct.
- Craddock was charged with violating the protection order under R.C. 2919.27(A)(2), a first-degree misdemeanor, and found guilty after a bench trial.
- Sentenced to one year probation, 180 days in jail (175 suspended), and fined $300. Craddock appealed the conviction, arguing insufficient or improper evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Evidence at trial proves violation of the order | Verdict not supported by sufficient evidence | Conviction supported by sufficient evidence; appeal denied |
| Manifest weight of the evidence | Testimony shows reckless violation of the order | Verdict against manifest weight of evidence | No manifest miscarriage of justice; conviction affirmed |
| Recklessness standard under R.C. 2919.27(A)(2) | Actions clearly reckless and in violation | Conduct not reckless or in violation | Defendant acted recklessly; order was violated |
| Admissibility and credibility of testimony | Witnesses’ testimony credible and consistent | Testimony not credible | Trial court best placed to weigh credibility; conviction stands |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259 (relevant inquiry for sufficiency of the evidence)
- State v. DeHass, 10 Ohio St.2d 230 (witness credibility is primarily for trier of fact)