State v. Davis, 2013 Ohio 1504

Dickey reported theft of multiple tools and equipment from his property in 2010; Hashman suspected of selling items to Davis’ Buy-Sell-Trade store.
Detective Emrick linked photographed items at Davis’ store to Dickey’s stolen items via transactions and a store receipt bearing the suspect’s name.
Detectives visited Davis’ store with a police report; Davis refused to disclose the current location of the items and noted no serial numbers on the report.
A warrantless follow-up search failed to locate the items; later, a search with a warrant also failed to locate them.
Davis was indicted by a Ross County Grand Jury for tampering with evidence under R.C. 2921.12 and convicted after trial.
Appeal followed challenging sufficiency and manifest-weight of the evidence supporting the tampering conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for tampering	Davis argues evidence failed to show he hid, altered, or removed items	Davis asserts no evidence showed purpose to impair investigation or the items were evidence	Sustained by Court: evidence showed concealment/removal and potential evidence sufficient
Conviction against manifest weight of the evidence	Davis contends evidence was not substantial/credible that items were same as Dickey’s theft items	Davis claims the state failed to prove the items were evidence in the Dickey investigation	Affirmed: record supported weight of evidence and credibility were for the jury

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (sufficiency/weight framework; standard for review of evidence)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard)
Jenks v. State, 61 Ohio St.3d 259 (Ohio 1991) (usahntil; standard of review for sufficiency)
State v. Eley, 56 Ohio St.2d 169 (Ohio 1978) (sufficiency/manifest weight guidance)
Disciplinary Counsel v. Robinson, 126 Ohio St.3d 371 (Ohio 2010) (tampering with evidence—value not absolute evidence required)