State v. Goins, 2022 Ohio 985

Goins was a staff member at a residential group home operated by CRSI caring for Brian, a disabled resident.
On Jan. 19, 2019 Brian fell; the coworker who witnessed the fall failed to report it and told Goins later that evening. Goins did not timely report the fall or abnormal behavior.
Brian was taken to the hospital on Jan. 21, 2019 with a hip fracture; discharge paperwork and pain‑medication prescriptions were given to his brother, who put them in Brian’s medical book at the group home.
Goins did not check the medical book, did not file the required incident report, and did not ensure prescriptions were filled; Brian missed a follow‑up appointment and did not receive prescribed pain medication until Jan. 23. He was later hospitalized again and died on Jan. 27, 2019.
Goins was charged with gross patient neglect, failing to provide for a functionally impaired person, and patient neglect. After a jury trial he was convicted of patient neglect (R.C. 2903.34(A)(3)), acquitted of gross patient neglect, and sentenced to jail with part suspended. He appealed.
On appeal Goins argued (1) insufficient evidence and manifest weight — no medical nexus proving his omissions caused Brian’s serious physical harm — and (2) ineffective assistance for failing to request a jury instruction on causation.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Goins)	Held
Sufficiency / causation for patient‑neglect conviction	Goins’ failure to report, failure to check the medical book, failure to ensure follow‑up or meds were provided were reckless omissions that were a substantial/contributing factual and proximate cause of Brian’s serious physical harm	There was no medical testimony or direct nexus showing Goins’ acts/omissions caused new or additional serious physical harm to Brian	Conviction affirmed — viewing evidence in State’s favor, a rational juror could find Goins’ reckless omissions were a contributing actual and proximate cause of serious physical harm; verdict not against manifest weight
Ineffective assistance for not requesting a causation jury instruction	Any omission was harmless because evidence was overwhelming; counsel’s decision on instructions was trial strategy and Goins cannot show prejudice	Counsel was ineffective for failing to request an instruction on causation, which could have helped rebut the causation element	Affirmed — no ineffective assistance: counsel’s choice was trial strategy and Goins cannot show a reasonable probability of a different outcome given the sufficiency of the evidence

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest‑weight review)
State v. Jenks, 61 Ohio St.3d 259 (1981) (standard for sufficiency review: evidence viewed in light most favorable to the prosecution)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑part test for ineffective assistance of counsel)
State v. DeHass, 10 Ohio St.2d 230 (1967) (deference to the trier of fact on witness credibility)
State v. Gardner, 118 Ohio St.3d 420 (2008) (defendant entitled to jury instruction on all elements of the offense)
State v. Kole, 92 Ohio St.3d 303 (2001) (application of ineffective‑assistance standard)