State v. Medley, 2018 Ohio 1391

Child born Jan. 27, 2016 lived with father (Medley) and mother (C.B.); suffered bilateral subacute subdural hematomas and retinal bleeding; injuries medically determined to be non-accidental and consistent with shaking.
Child hospitalized twice in May 2016; second hospitalization followed grandmother finding the child with abnormal eye movement and a swollen head; 9-1-1 called and child taken to Rainbow Babies & Children’s Hospital.
Medical testimony: MRI showed bilateral subacute subdural hematomas (7–21 days old); retinal hemorrhages present; no evidence of blunt-force trauma; treating physician opined injury caused by shaking.
Law enforcement investigated, obtained search warrant for the home (found a hat father said had been kept on the child for days); child placed in foster care upon discharge.
Appellant and mother jointly tried; jury acquitted appellant of the higher felony count but convicted him of misdemeanor child endangerment (R.C. 2919.22(A)); sentenced to two years community control.
Appellant appealed arguing insufficiency and that the verdict was against the manifest weight of the evidence; appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict Medley of child endangerment	State: Medical and circumstantial evidence (subacute bilateral SDH, retinal hemorrhages, limited caregivers, appellant’s statements) suffice to show Medley created a substantial risk by reckless conduct	Medley: State failed to prove he directly caused the injury or that he was responsible for the abuse	Held: Evidence sufficient; jury could reasonably find Medley violated duty of care and created substantial risk (recklessness proven)
Manifest weight of the evidence	State: The weight of medical opinion and circumstantial evidence supports conviction	Medley: Verdict against manifest weight because direct proof he caused injury lacking and other caretakers existed	Held: Not against manifest weight; trier of fact did not lose its way — conviction affirmed

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest-weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency: viewing evidence in light most favorable to prosecution)
Jackson v. Virginia, 443 U.S. 307 (1979) (reasonable-doubt sufficiency standard; defer to factfinder’s credibility determinations)
State v. Yarbrough, 95 Ohio St.3d 227 (2002) (credibility and weight of evidence are primarily for the trier of fact)
State v. Biros, 78 Ohio St.3d 426 (1997) (circumstantial evidence has same probative value as direct evidence)