State v. Golga, 2024 Ohio 1410

The City of North Ridgeville shut off Matthew Golga's water due to nonpayment, prompting Golga to call the City Water Department 8 times in 26 minutes, becoming increasingly irate, using profanity, and leaving an aggressive voicemail.
Water Department employees felt harassed and threatened by the repeated profane calls and voicemail, leading the message to be referred to police.
Golga was charged with telecommunications harassment under Ohio law (R.C. 2917.21(A)(1)).
He was convicted by a jury and sentenced to 180 days in jail (177 suspended) and anger management, then appealed.
On appeal, Golga argued that he called for a legitimate purpose (restoring water) and had no specific intent to harass, intimidate, or abuse.
The appellate court reviewed sufficiency of the evidence de novo, focusing on whether Golga acted with the required intent under the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for conviction	Golga had a legitimate purpose in calling and no intent to harass	Golga's conduct showed intent to harass, intimidate, or abuse	Reversed: No evidence of purposeful intent
Definition of intent under R.C. 2917.21(A)(1)	Must show specific purpose to harass/intimidate/abuse	Golga's actions sufficiently prove specific intent	Focus is on purpose, no direct proof found
First Amendment implications	Application could chill citizen petition rights	Not directly addressed	Court concurred, cautioning future chilling
Weight of testimonies about impact on employees	Employees felt harassed and afraid	Impact not legally dispositive to intent	Jury’s finding insufficiently supported

State v. Thompkins, 78 Ohio St.3d 380 (standard of review for sufficiency of evidence)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency of evidence standard for criminal convictions)
State v. Cress, 112 Ohio St.3d 72 (definition of intimidation under Ohio law)