State v. Enoch, 2020 Ohio 3406

Terrance Enoch was charged with first-degree misdemeanor domestic violence for an incident on Jan. 18, 2019 involving Aries Goens, the mother of his child.
Goens testified at a bench trial that Enoch threw a shoe (one hit her), smacked her twice with an open hand, punched her, pushed her into a wall, and tried to grab their child; she claimed resulting swelling and bruising.
Officer Cheryl Lambing arrived after the incident, took photographs, but testified she observed no visible injuries on the evening of the incident; Goens later took photos a day or two after showing swelling/bruising.
Defense witnesses (the officer and Enoch’s mother) disputed visible injuries and provided a different account; Enoch denied striking Goens beyond tossing a shoe.
The trial court found Goens credible, relied on testimony and photographs, convicted Enoch of domestic violence, and sentenced him to community control, jail time (partially suspended), classes, and fines; Enoch appealed.

Issue	State's Argument	Enoch's Argument	Held
Sufficiency: whether evidence proved "physical harm" under R.C. 2919.25(A)	Victim’s testimony plus photos showed swelling/bruising caused by Enoch	No proof of physical harm; officer saw no injuries; photos and statements unreliable	Evidence sufficient: testimony + photos supported physical-harm element
Manifest weight: whether conviction was against the manifest weight of the evidence	Trial court as factfinder properly credited victim and reconciled inconsistencies	Victim’s statements were inconsistent; possible fabrication (makeup background); officer testimony favored acquittal	Not against manifest weight: court reasonably credited victim and photographic evidence; conviction affirmed

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency review from manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency: whether any rational trier of fact could find elements proven beyond a reasonable doubt)