State v. Dyer, 2023 Ohio 544

On Sept. 9, 2021, Carmen Dyer was arrested and charged with one count of domestic violence under R.C. 2919.25(A) (knowingly cause or attempt to cause physical harm to a family member).
Deputy Luke Craft responded to a call; he testified that he saw Dyer dragging her 17‑year‑old daughter (N.D.) by the hair, jacket, and book bag, with N.D. screaming; no visible injury or complaints of pain were observed.
The only State witness was Deputy Craft (body‑cam captured several seconds of N.D.’s screaming). The jury convicted Dyer; she moved for a Crim.R. 29 judgment of acquittal which was denied.
Dyer testified she only tried to remove N.D. from the house so Dyer could seek medical care and denied attempting to harm her daughter; she claimed N.D. threw herself down.
Dyer appealed, arguing insufficient evidence because there was no proof of physical harm and her purpose was to get N.D. out of the house, not to injure her.
The trial court sentenced Dyer to a suspended 90‑day jail term (conditioned on no similar violations for two years); the appellate court reviewed the sufficiency claim.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Dyer)	Held
Whether evidence was sufficient to convict under R.C. 2919.25(A) (knowingly cause or attempt to cause physical harm)	Deputy Craft’s testimony that Dyer dragged N.D. by hair, jacket, and book bag supports that Dyer acted knowingly and attempted to cause physical harm	No physical harm occurred and Dyer’s purpose was to remove N.D. from the house to go to the hospital, not to harm her	Affirmed: a rational juror could find Dyer acted knowingly in attempting to cause physical harm by dragging N.D.; purpose is irrelevant to the ‘‘knowingly’’ mental state

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sets the sufficiency‑of‑the‑evidence standard on appeal)
State v. Nielsen, 66 Ohio App.3d 609 (Ohio Ct. App. 1990) (attempt to cause physical harm is sufficient for domestic violence even if no actual physical injury occurred)