State v. Gerdes, 2019 Ohio 913

Anne Gerdes and husband Martin had marital difficulties; Gerdes locked their bedroom door while sleeping.
Martin unlocked the door with a screwdriver, entered to get a blanket and noticed his alarm clock was unplugged.
An altercation occurred when Martin reached over the headboard to plug in the clock: Martin testified Gerdes hit him with a pillow, kicked his side multiple times, and crushed his arm between the headboard and wall; he felt soreness the next day.
Gerdes denied striking Martin, asserting she only used her foot to push him off and acted out of fear/self-defense.
Gerdes was charged with and convicted by a jury of one count of domestic violence (R.C. 2919.25(A)) in Hamilton Municipal Court; she appealed on sufficiency and manifest-weight grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove "physical harm" under R.C. 2919.25(A)	State: Martin's testimony that he was struck, kicked, and had his arm crushed, plus soreness next day, suffices to show physical harm	Gerdes: No observable injury; contact was defensive or minor and thus insufficient to prove physical harm	Affirmed — testimony, including soreness next day, was sufficient to support conviction
Manifest weight of the evidence (credibility of witnesses)	State: Jury could reasonably credit Martin's version over Gerdes' denials	Gerdes: The jury should have found her self-defense claim and rejected Martin's testimony	Affirmed — appellate court found jury did not lose its way; credibility choice was for the jury

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for sufficiency review)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (standard for manifest-weight review)