State v. Holloway, 2025 Ohio 1637

Carmendy Holloway was charged with operating a vehicle while impaired (OVI), driving under suspension, improper turn signal, and speeding after a bench trial.
Officer Rian Jackson observed Holloway speeding and failing to use a turn signal, and upon stopping her, detected signs of alcohol impairment.
Holloway declined to perform field-sobriety tests and denied consuming alcohol, but the officer observed slurred speech, glossy eyes, odor of alcohol, and stumbling.
Holloway argued at trial that there was insufficient evidence of impairment and that venue was not established.
The trial court found Holloway guilty on all charges; Holloway appealed her OVI conviction on sufficiency and manifest weight of evidence grounds.
On appeal, the court also considered whether sufficient evidence established that the offenses occurred within the proper venue (Hamilton County).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Evidence for OVI	Officer’s testimony and circumstantial evidence showed impairment	No direct evidence of impairment or erratic driving	Evidence was sufficient to uphold OVI conviction
Weight of the Evidence	Testimony and physical indicia supported conviction	Evidence did not credibly establish impairment	Conviction was not against manifest weight of the evidence
Proof of Venue	Circumstantial evidence established incidents occurred in Hamilton County	State failed to directly prove venue	Circumstantial evidence was sufficient to establish venue
Issues in Cases B/C/D	No challenge from Holloway	Not explicitly argued	Appeal dismissed in part due to no challenge

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (clarifies sufficiency of the evidence standard)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (explains reviewing challenges to weight of the evidence)
State v. Draggo, 65 Ohio St.2d 88 (Ohio 1981) (establishes requirement for proof of venue)
State v. Headley, 6 Ohio St.3d 475 (Ohio 1983) (venue may be proven by facts and circumstances)