State v. Eslich, 2014 Ohio 4640

Amber Eslich owned a Louisville residence advertised on Backpage.com offering "massages" and describing herself as an "experienced seductress." Police surveilled the property after complaints of heavy foot traffic.
Canton Detective Gaug posed as a customer, scheduled a massage, and during the session Eslich removed clothing and performed oral sex; the detective asked whether sexual acts would cost more and how much.
Eslich admitted to performing oral sex but maintained it was not negotiated or solicited as a sex-for-hire arrangement and that the $100 massage price had been discussed without bargaining for sex.
The jury convicted Eslich of one count of soliciting for prostitution (R.C. 2907.24), and she was sentenced to 60 days with 30 days suspended.
On appeal, Eslich challenged the denial of her Crim.R. 29 motion, arguing insufficient evidence and that the verdict was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to support a conviction for soliciting (entice/ask another to engage in sexual activity for hire)	State: advertisement, disclaimer, detective's questioning about price, and Eslich's statements that a "hand release" was included supported solicitation for hire	Eslich: sexual acts were consensual and not discussed or negotiated as an exchange for money; no solicitation occurred	Court: evidence (including circumstantial) was sufficient; conviction affirmed
Whether the verdict was against the manifest weight of the evidence	State: jury properly weighed credibility and could reasonably find solicitation beyond a reasonable doubt	Eslich: inconsistencies and testimony show alternative reasonable view that no solicitation occurred	Court: not an exceptional case; jury did not lose its way; weight issue for factfinder, conviction upheld

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency review standard under due process)
McDaniel v. Brown, 558 U.S. 120 (reaffirming Jackson sufficiency standard)
State v. Jenks, 61 Ohio St.3d 259 (Ohio standard for circumstantial evidence equals direct evidence)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard and role of appellate court as "thirteenth juror")
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (appellate deference when evidence admits multiple constructions)
State v. Lott, 51 Ohio St.3d 160 (permissible inferences from same facts)
State v. DeHass, 10 Ohio St.2d 230 (credibility and weight of evidence reserved to trier of fact)