State v. Haley, 2014 Ohio 2515

Defendant Thomas J. Haley was charged with and convicted after a bench trial of one count of criminal trespass under R.C. 2911.21(A)(1) for entering Melanie Erman’s home on November 14, 2013.
Erman testified Haley entered through the back door without knocking; a privacy fence surrounded the yard and Haley had no permission to enter unannounced.
Six months earlier Haley had an altercation with Erman’s husband and had been told by the deputy and the husband he was not welcome at the residence.
During the encounter Erman told Haley to leave multiple times; Haley was briefly permitted to use the phone and then left, but deputies later sought him and charged him with trespass.
The trial judge convicted Haley after a bench trial; Haley appealed arguing the conviction was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction is against the manifest weight and sufficiency of the evidence	State: testimony showed Haley knowingly entered without privilege and remained after being told to leave	Haley: conviction is against the manifest weight of the evidence	Affirmed — evidence was sufficient and conviction was not against the manifest weight

Jackson v. Virginia, 443 U.S. 307 (establishes standard for constitutional sufficiency review)
McDaniel v. Brown, 558 U.S. 120 (reaffirms Jackson sufficiency standard)
State v. Thompkins, 78 Ohio St.3d 380 (explains manifest-weight review and that reversal is reserved for exceptional cases)
Seasons Coal Co., Inc. v. Cleveland, 10 Ohio St.3d 77 (instructs appellate courts to give evidence the construction most favorable to sustaining verdict)
Allstate Fire Ins. Co. v. Singler, 14 Ohio St.2d 27 (definition of trespasser—unauthorized entry without invitation)
State v. DeHass, 10 Ohio St.2d 230 (credibility and weight of witness testimony are for the trier of fact)