State v. Jackson, 2023 Ohio 785

Jonathan Jackson was charged with domestic violence (R.C. 2919.25(A)) for knowingly causing physical harm to his wife, Christin, by grabbing her phone and physically forcible conduct in their bedroom.
Christin testified Jackson burst into the bedroom, demanded her phone, knocked her out of bed, tackled her, jumped on her back, hit/grabbed/squeezed her arms, and scratched her chest; photographs of bruising and a scratch were admitted.
Their son testified he saw Jackson on top of Christin; Christin’s father testified Jackson admitted grabbing and holding Christin down and accompanied Christin to file a police complaint the next day (officers had not charged Jackson the night of the incident).
Jackson testified he suspected an affair and wrestled with Christin over her phone, denying he intended to harm her or to strike or squeeze her.
After a bench trial the court convicted Jackson, imposed a suspended jail term, community control (including no-contact), a fine, and costs. Jackson appealed.
On appeal Jackson challenged (1) sufficiency and weight of the evidence supporting the conviction and (2) the statutory definition of “physical harm,” asking the court to narrow it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency and weight of evidence that Jackson knowingly caused physical harm	State: Victim’s testimony, son’s corroboration, father’s admission and injury photos suffice to prove elements beyond a reasonable doubt	Jackson: He only wrestled for the phone, had no intent to harm; officers initially declined to charge	Conviction affirmed: evidence sufficient and conviction not against manifest weight; court credited victim and corroborating witnesses
Whether the court should narrow the statutory definition of “physical harm”	State: R.C. 2901.01(A)(3) defines physical harm broadly; even slight injury suffices under existing law	Jackson: Definition is overbroad and criminalizes trivial family disputes; court should reform the definition	Court refused to rewrite the statute: definition is legislative, not judicial, and must be applied as written

State v. Walker, 150 Ohio St.3d 409, 82 N.E.3d 1124 (2016) (articulates sufficiency standard and applies Jenks)
State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (1991) (sufficiency-of-the-evidence test)
State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (1997) (manifest-weight review standard)
State v. DeHass, 10 Ohio St.2d 230, 227 N.E.2d 212 (1967) (trial court credibility determinations are entitled to deference)
State v. Daniels, 111 N.E.3d 708 (2018) (applies statutory definition that the slightest injury can constitute physical harm)
Jacobson v. Kaforey, 149 Ohio St.3d 398, 75 N.E.3d 203 (2016) (explains courts must apply statutes as written and the legislature defines criminal terms)