State v. Freeman, 2023 Ohio 3745

Freeman was charged with one count of first-degree misdemeanor assault (R.C. 2903.13(A)) after an incident alleged to involve striking the victim with a baseball bat.
Bench trial took place April 4, 2023; the State presented testimony from the victim and an independent eyewitness, both saying Freeman hit the victim with a bat causing physical harm.
Freeman testified and denied the assault, claiming her brother and another boy were the perpetrators; her brother also testified.
The trial court found Freeman (and her brother) not credible, convicted Freeman, and imposed jail time, fines, and community control with anger‑management and no‑contact conditions.
Freeman appealed, arguing the conviction was against the manifest weight of the evidence due to alleged inconsistencies and unreliability of the State's witnesses.
The Twelfth District Court of Appeals affirmed the conviction, holding the inconsistencies were minor and credibility determinations are for the trier of fact.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Freeman's assault conviction is against the manifest weight of the evidence	The State: Victim and independent eyewitness testimony, if believed, proves Freeman knowingly caused physical harm by striking the victim with a bat	Freeman: Witness testimony was unreliable and inconsistent (location of injury); she denied committing the assault and blamed others	Affirmed: Conflicts were minor; credibility is for the trier of fact; evidence did not weigh heavily against the conviction

State v. DeHass, 10 Ohio St.2d 230 (establishes that credibility determinations are for the trier of fact)
State v. Wilks, 154 Ohio St.3d 359 (explains manifest-weight review framework)
State v. Hundley, 162 Ohio St.3d 509 (recognizes manifest-weight overturn is reserved for extraordinary circumstances)
State v. Berry, 159 Ohio App.3d 476 (minor inconsistencies in testimony do not render testimony inherently unworthy of belief)