State v. Craig, 2022 Ohio 1219

In August 2019 Craig was indicted for felonious assault, domestic violence, and tampering with evidence arising from a stabbing of his roommate, Albert Harper Jr.
Harper flagged down a police officer soon after being stabbed; he had surgery and stayed in the hospital three weeks.
Craig told detectives he stabbed Harper in defense of his common‑law wife, admitted removing the knife from the residence, and said he tossed the knife out of the vehicle while fleeing and being chased.
At trial the jury acquitted Craig of felonious assault and domestic violence but convicted him of tampering with evidence; the court sentenced him to two years imprisonment.
Craig appealed, arguing the tampering conviction was unsupported by sufficient evidence and was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict for tampering with evidence	State: Craig admitted disposing of the knife; a reasonable juror could infer he knew an investigation was likely and intended to impair evidence	Craig: He reasonably believed Harper would not call police, so no likely investigation; lacked the requisite purpose to impair evidence	Affirmed. Evidence—Craig's admissions and circumstances—was sufficient to permit a rational juror to find knowledge and purposeful disposal beyond a reasonable doubt
Manifest weight of the evidence	State: Credible evidence and Craig's admissions support the verdict; jury properly weighed credibility	Craig: Jury clearly erred in relying on his statements to infer intent and likelihood of an investigation	Affirmed. Exercising deference to the jury's credibility determinations, the court held the verdict was not against the manifest weight of the evidence

State v. Thompkins, 78 Ohio St.3d 380 (distinguishing sufficiency and manifest‑weight review)
State v. Tenace, 109 Ohio St.3d 255 (standard for sufficiency review)
State v. Straley, 139 Ohio St.3d 339 (likelihood of investigation measured at time of alleged tampering)
State v. Garner, 74 Ohio St.3d 49 (intent inferred from surrounding circumstances)
State v. Carter, 72 Ohio St.3d 545 (intent lies within defendant's private thoughts and may be inferred)
State v. Grant, 67 Ohio St.3d 465 (trier of fact may infer intent from the totality of the circumstances)
State v. DeHass, 10 Ohio St.2d 230 (credibility and weight of testimony for trier of fact)
State v. Antill, 176 Ohio St. 61 (jury may believe all, part, or none of witness testimony)
State v. Martin, 20 Ohio App.3d 172 (reversal on manifest‑weight grounds reserved for exceptional cases)
Tibbs v. Florida, 457 U.S. 31 (appellate court acting as a "thirteenth juror" when assessing weight of the evidence)