State v. Glover, 2012 Ohio 165

Glover was convicted by a jury of one count of retaliation under R.C. 2921.05(A).
He appeared for a video arraignment in Rocky River Municipal Court on a shoplifting charge.
During transport to the county jail, Glover spoke aggressively and threatened the judge, saying he would “find that bitch judge and fuck her up.”
A patrol car video recorded Glover’s conduct; audio was largely obscured by road noise but officers corroborated the threats.
Glover appealed asserting the evidence was insufficient to prove the requisite intent to threaten; the appellate court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient to prove intent to threaten?	Glover argues no proof of intent beyond mere harsh language.	State contends the threats were earnest and unambiguous.	Yes; evidence sufficient to prove intent beyond reasonable doubt.

State v. Tenace, 109 Ohio St.3d 255 (2006-Ohio-2417) (sufficiency standard for Crim.R.29 and verdicts)
State v. Nicely, 39 Ohio St.3d 147 (1988-Ohio-1236) (circumstantial and direct evidence have equal probative value)
State v. Jenks, 61 Ohio St.3d 259 (1991-Ohio-237) (direct vs. circumstantial evidence standard; equal probative value)
State v. Nayar, 2007-Ohio-6092 (4th Dist.) (threats conveyed to third party can satisfy retaliation element)
State v. Oliver, 2009-Ohio-228 (8th Dist.) (reckoned as supported by video/audio evidence)
State v. Farthing, 2001-Ohio-7077 (2nd Dist.) (threats made in confidence and admissibility considerations)