State v. Myers, 2022 Ohio 991

Early May 22, 2020: police responded to an apparent overdose death (victim S.M.) at an apartment; several people were present and Jacob Myers was later located sleeping in the basement.
Later that day three women (including J.B.) and another individual reported to police that Myers held occupants at gunpoint, prevented them from leaving, and prevented them from rendering aid to S.M.
J.B. testified C.R. handed Myers a gun, Myers stood at the front door blocking egress for about 90 minutes, took/ended her 911 call and prevented others from calling; she testified she feared for her life.
At trial the jury convicted Myers of kidnapping and abduction as to J.B., found firearm specifications true, and convicted him of having a weapon while under disability and disrupting public services; other kidnapping/abduction counts were acquitted.
Sentencing: 6–9 years for kidnapping plus a mandatory 3-year firearm term; concurrent shorter terms imposed on the remaining convictions.
On appeal Myers argued convictions were unsupported by sufficient evidence and against the manifest weight of the evidence, and that trial counsel provided ineffective assistance (failure to obtain text records and inadequate communication). The Ninth District affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Myers)	Held
Sufficiency and manifest weight of evidence for kidnapping/abduction	Testimony (J.B.) and officer evidence support that Myers held J.B. at gunpoint, restrained her liberty, and intended to terrorize/coerce her; jury entitled to credit that evidence	J.B.’s credibility impaired by LSD use; other witnesses testified no restraint occurred	Court: Evidence was sufficient and weight did not favor reversal — convictions affirmed
Possession while under disability & disrupting public services	J.B. identified Myers as possessing the gun for ~90 minutes; taking/ending her 911 call impaired telephone service	Myers disputed continuous possession and challenged application of disrupting-public-services statute	Court: Evidence supports weapon possession under disability and that Myers prevented 911 calls; convictions affirmed
Ineffective assistance of counsel	N/A (State defends adequacy)	Counsel failed to obtain text-message records and failed to communicate adequately; these errors prejudiced defense	Court: Strickland standard requires record support; record lacks the text messages and communication details, so claim fails on direct appeal

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for sufficiency review)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance two‑prong test)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishing sufficiency and manifest‑weight review)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency review and appellate standard)
Eastley v. Volkman, 132 Ohio St.3d 328 (Ohio 2012) (manifest‑weight standard formulation)
State v. Hartman, 93 Ohio St.3d 274 (Ohio 2001) (mental state and purposeful removal/restraint in kidnapping)
State v. Otten, 33 Ohio App.3d 339 (Ohio Ct. App. 1986) (framework for weighing evidence and manifest‑weight reversal)
State v. Martin, 20 Ohio App.3d 172 (Ohio Ct. App. 1983) (rare use of manifest‑weight reversal)