State v. Middleton, 2013 Ohio 1848

Middleton was charged under R.C. 2919.24(A)(2) for recklessly contributing to her daughter's unruliness due to school absences.
A juvenile court magistrate found Middleton guilty; the trial court adopted the magistrate's decision after objections.
The complaint alleged 24 absences with 14 unexcused; testimony focused on unexcused absences and tardies.
Attendance officer Wysong testified Middleton's daughter had 13 unexcused absences; letters and reminders were sent to Middleton.
Middleton claimed legitimate medical issues and an IEP; she argued the school was at fault for tardiness and absences.
The court held the evidence supported a finding of recklessness and affirmed the conviction as not against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Manifest weight supports conviction?	State argues 13+ unexcused absences establish habit of truancy.	Middleton contends genuine excuses exist and school staff share blame.	Conviction affirmed; weight supports finding.

State v. Moody, 104 Ohio St.3d 244 (Ohio 2004) (recklessness standard applies to contributing to the unruliness of a minor)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (weight of evidence standard and appellate review)
State v. Hancock, 108 Ohio St.3d 57 (Ohio 2006) (weight and credibility of evidence reserved for the trier of fact)
State v. DeHass, 10 Ohio St.2d 230 (Ohio 1967) (credibility and weight are for the trier of fact)
State v. Kindle, 2003-Ohio-302 (3d Dist. No. 5-02-21 (Ohio) 2003) (conduct tending to cause unruliness need not prove actual unruliness)