Background - Levenski Crossty entered a house-sitting residence uninvited through a window, encountered Jessica Wilson and her four children, forced open a locked bathroom door, and assaulted Wilson. - Wilson was rendered at least momentarily unconscious, later found as a passenger in a car driven by Crossty with her children in the vehicle; Crossty repeatedly struck and screamed at her over several hours. - Wilson briefly escaped with her toddler at a fast-food drive-through; Crossty grabbed the child and fled. Wilson required hospital treatment for extensive bruising, lacerations, swelling, and abrasions. - Crossty was indicted on multiple counts including aggravated burglary, felonious assault, abduction, kidnapping, and theft; convicted by a jury of aggravated burglary, felonious assault, and a single count of abduction (others acquitted or dismissed). - Crossty challenged (1) weight and sufficiency of the evidence for the convictions, (2) admission/authentication of a recorded jail phone call, and (3) the imposition of consecutive sentences. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---|---| | Aggravated burglary — trespass/consent to enter | State: testimony showed Crossty entered without consent and assaulted Wilson inside an occupied structure | Crossty: owner or Wilson had consented; no proof consent was revoked | Court: Sufficient evidence of trespass; assault in home gave rise to inference privilege to remain was revoked; conviction upheld | | Felonious assault — serious physical harm element | State: medical treatment and photographs showed bruising, lacerations, swelling, disfigurement, acute pain sufficient for serious physical harm | Crossty: injuries not severe enough to meet statutory "serious physical harm" | Court: Photographs and treatment supported serious-physical-harm under R.C. definitions; conviction upheld | | Abduction — removal by force or threat | State: evidence that Crossty knocked Wilson out, forcibly moved her into car and regrabbed her when she tried to flee | Crossty: Wilson could not recall how she got into the car, so removal not proved | Court: Jury could infer forcible removal from the blow and Crossty’s admissions; conviction upheld | | Authentication of jail-call recording | State: detective traced call via jail logs, recognized voices from interviews and recordings, established reasonable likelihood of authenticity | Crossty: chain-of-custody/authentication insufficient to admit recording | Court: Admission was proper; foundation sufficient and any breaks affect weight not admissibility | | Consecutive sentences — R.C. 2929.14(C) findings | State: sentencing court articulated statutory findings and incorporated them into entry | Crossty: record lacked support for mandatory findings (e.g., prior record) | Court: Defense counsel acknowledged prior felony; court made required findings on the record and explained reasons; consecutive sentences affirmed | ### Key Cases Cited State v. Jenks, 61 Ohio St.3d 259 (setting sufficiency-of-the-evidence standard) State v. Thompkins, 78 Ohio St.3d 380 (weight-of-the-evidence standard; "thirteenth juror") State v. Steffen, 31 Ohio St.3d 111 (assault in residence can revoke permission to remain and support trespass) State v. Gross, 97 Ohio St.3d 121 (chain-of-custody not required to be unbroken for admissibility; breaks go to weight) * State v. Bonnell, 140 Ohio St.3d 209 (trial court must make required consecutive-sentence findings on the record)