State v. Jenkins, 2021 Ohio 1978

On March 7, 2020, Desirae Hall went to the home of Terrance Jenkins’s father to drop off their children; Jenkins removed Hall’s phone from the car and began searching it.
When Hall returned to the car and confronted Jenkins about the phone, he shoved the phone into his pocket and violently assaulted her—punching, kicking, and strangling her while making threats to kill.
Two passersby (Corey and Dakota Thoman) saw the beating, stopped, and intervened; Jenkins fled the scene. Hall sustained severe facial fractures, lacerations, and neck bruising consistent with strangulation.
A grand jury indicted Jenkins for attempted murder (1st degree felony), aggravated robbery (1st degree felony), felonious assault (2nd degree felony), and domestic violence (1st degree misdemeanor).
Jenkins proceeded to a bench trial, was found guilty on all counts (trial court merged the convictions into attempted murder for sentencing), and was sentenced to 9–13.5 years.
Jenkins appealed, challenging (1) the manifest weight of the evidence as to attempted murder (intent to kill) and (2) the sufficiency of evidence for aggravated robbery (arguing the theft was complete before the assault and force served a separate animus).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jenkins’s attempted murder conviction was against the manifest weight of the evidence (intent to kill)	State: surrounding circumstances (jealous, controlling behavior; threats during assault; strangulation; severity of injuries) permit an inference of intent to kill	Jenkins: intent to kill not shown; testimony of threats was hearsay/impeached; crime was a crime-of-passion or loss of control	Affirmed — court found ample evidence (threats, strangulation, brutality, expert testimony on strangulation as lethal) to infer intent to kill; conviction not against manifest weight
Whether evidence was sufficient to support aggravated robbery when the theft allegedly preceded the assault and victim was immediately aware	State: Jenkins took Hall’s phone without consent (placed it in his pocket and did not return it) and contemporaneously inflicted serious physical harm	Jenkins: theft was completed before force; force was committed for separate animus (domestic violence), not to effectuate theft or escape	Affirmed — court held Hall was aware of the theft, Jenkins intended to deprive her of the phone, and the serious physical harm occurred contemporaneously with the theft, satisfying aggravated robbery elements

State v. Martin, 20 Ohio App.3d 172 (manifest-weight standard and when to grant a new trial)
State v. Thompkins, 78 Ohio St.3d 380 (clarifying manifest-weight standard)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency standard following Jackson)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
State v. Wallen, 21 Ohio App.2d 27 (intent may be inferred from surrounding facts and circumstances)
State v. Robinson, 161 Ohio St. 213 (trier of fact may infer intent to kill from circumstances)