State v. Jackson, 131 N.E.3d 378

Background

On Sept. 27, 2017, Kareem T. Jackson allegedly forced entry into the home of his estranged girlfriend, Renae Fearing, struck her repeatedly, threw her cell phone against a wall, and took cash. He had previously lived with Fearing and had five prior domestic-violence convictions (stipulated).
Initially charged in municipal court; grand jury indicted on: Count 1 — domestic violence (R.C. 2919.25(A)) (third-degree felony); Count 2 — robbery (acquitted); Count 3 — disrupting public services (R.C. 2909.04(A)(3)) (fourth-degree felony).
At trial the State presented Fearing, neighbors who heard/observed the commotion, and a police sergeant who observed fresh bruising and door damage; photographic exhibits showed bruising and a splintered doorframe and the phone in multiple pieces and in an inaccessible location.
Jackson testified he only went to retrieve belongings, denied entering the house or hurting Fearing, and disputed causation of the injuries; he also acknowledged prior convictions.
Jury convicted Jackson of domestic violence (Count 1) and disrupting public services (Count 3); sentenced to concurrent prison terms (36 months on Count 1; 18 months on Count 3). Jackson appealed, arguing insufficient evidence and manifest weight errors.

Issues

Issue	State's Argument	Jackson's Argument	Held
Sufficiency — domestic violence: whether evidence proves Jackson knowingly caused or attempted to cause physical harm to a household member	Fearing’s testimony, corroborating photos, neighbors’ observations, and officer’s observations of fresh bruising and door damage suffice to prove knowing causing/attempt to cause physical harm	Only Fearing directly testified to causation; injuries were minor (redness/knots) and she did not seek treatment — insufficient proof	Affirmed: viewing evidence in the light most favorable to the prosecution, a rational trier of fact could find the elements proven
Manifest weight — domestic violence: whether verdict is against the weight of the evidence given conflicting testimony	Credibility determinations were for the jury; corroborating evidence supports the verdict	Jury improperly credited Fearing over Jackson; verdict against weight	Affirmed: appellate court will not substitute credibility judgments; verdict not a manifest miscarriage of justice
Sufficiency — disrupting public services: whether evidence shows Jackson damaged/tampered with property (cell phone) and substantially impaired emergency response ability	Throwing the phone made it inaccessible at the time Fearing needed to call 911; phone constitutes property/telecommunications device; inability to call is sufficient to show substantial impairment	No proof Jackson had purpose to impair emergency response; phone remained operable when later found	Affirmed: evidence permitted a rational jury to find tampering/damage and substantial impairment (and purpose inferred from circumstances)
Manifest weight — disrupting public services: whether verdict is against the weight of the evidence on intent and impairment	Intent to prevent calling can be inferred from breaking in and immediately taking/throwing the phone; neighbors and officer corroborate inaccessibility and condition of phone	Lack of direct proof that Jackson knew Fearing was trying to call or that he intended to impair emergency services; phone later worked	Affirmed: totality of circumstances supports jury’s inference of purpose and substantial impairment; not an exceptional case to overturn

Key Cases Cited

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishing sufficiency and manifest-weight standards)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for sufficiency review: evidence viewed in light most favorable to prosecution)
State v. Robinson, 124 Ohio St.3d 76 (Ohio 2009) (R.C. 2909.04(A)(3) requires damaging/tampering with property such as telecommunication devices to substantially impair emergency response)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility and weight of evidence are primarily for the factfinder)