State v. Hansen, 2013 Ohio 1735

Hansen threatened to blow up the Tiffin Municipal Court courthouse after learning her boyfriend faced jail time.
Police later searched the courthouse and other offices but found no explosive device.
Hansen was charged with making a terroristic threat in violation of R.C. 2909.23(A)(c).
She was indicted on one count under R.C. 2909.23(A)(1)(c),(2),(C) and tried by a jury.
The jury convicted Hansen; the trial court sentenced her to 18 months in prison.
Hansen appeals raising eight assignments of error challenging speedy-trial timing, evidence rulings, subpoenas, sufficiency/weight of proof, and counsel performance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy trial discharge	Hansen tolling invalid; indictment date used to toll timing.	Timeliness within 270 days; discovery bill tolled after indictment.	Discharge denied; speedy-trial time within limits.
Admission of post-threat phone/arrest recordings	Recordings irrelevant and prejudicial since after the threat; no identity issue.	Recordings show identity, motive, and continuity of threat.	No abuse; recordings admissible for identity, motive, or purpose.
Quash of subpoena for court security plan	Security plan relevant to seriousness of threat.	Plan was draft/formally adopted; court allowed in chambers; not admissible.	No abuse; trial court did not err in granting quash.
Sufficiency/weight of the evidence for conviction	Evidence showed reasonable fear or expectation of imminent offense.	Insufficient evidence that threat created fear or was taken seriously.	Conviction supported by sufficient evidence and not against weight.
Ineffective assistance of counsel	Voir dire failure to probe juror ties to law enforcement prejudiced defense.	No shown relationship; voir dire strategy prerogative; no prejudice.	No ineffective assistance; defense did not show prejudice.

State v. Bridgeman, 55 Ohio St.2d 261 (1978) (sufficiency/manifest weight standard reference)
State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency of evidence standard)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (weight of the evidence and credibility evaluation)
State v. Masters, 172 Ohio App.3d 666 (2007) (mixed question of law and fact; appellate review standard)