State v. Nash, 2022 Ohio 1516

Jordan Nash was charged with misdemeanor domestic violence (R.C. 2919.25(A)) and aggravated menacing (reduced to fourth‑degree menacing, R.C. 2903.22) after a domestic altercation with then‑wife Antoinette Nash.
Antoinette testified Nash grabbed a broom, struck a child, forced her against blinds, slammed and restrained her, seized her phone, brandished a firearm while reading texts, and threatened suicide when leaving the home.
Police observed bruising on Antoinette, damaged blinds at the scene, and a handgun magazine in Nash’s vehicle; Antoinette left the home with the children and stayed elsewhere following the incident.
Nash testified he was struck on the shin with a hammer by Antoinette, denied pushing her or brandishing a gun, and said he had not owned a firearm for years; his mother corroborated he had a swollen, reddened leg after the incident.
The trial court convicted Nash of first‑degree misdemeanor domestic violence and fourth‑degree menacing; Nash appealed, asserting (1) convictions were against the manifest weight of the evidence and (2) ineffective assistance of counsel for not admitting photographs of his leg injury.
The appellate court reviewed credibility disputes and the record, found no basis to overturn the convictions, and affirmed the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nash’s convictions were against the manifest weight of the evidence	Prosecution argued the victim’s testimony, observed bruising, damaged blinds, and the magazine supported convictions	Nash argued witness inconsistencies, victim’s motive to fabricate, and mother’s testimony undermined victim’s injuries	Court held convictions were not against the manifest weight; credibility decisions favored the state and evidence as a whole supported convictions
Whether Nash received ineffective assistance for failure to introduce photos of his leg injury	State argued no showing that photos exist or that omission was prejudicial; counsel’s choices reasonable	Nash argued counsel was unreasonable for not introducing photos that could impeach the victim and affect credibility	Court held Nash failed to prove deficient performance or prejudice; no evidence photos existed and no reasonable probability of a different outcome

State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (1997) (standard for manifest‑weight review—appellate court as thirteenth juror)
State v. Sipple, 170 N.E.3d 1273 (2021) (reiterating high bar for reversing on manifest weight)
State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (1983) (manifest‑weight reversal limited to cases where evidence weighs heavily against conviction)
State v. Sanders, 94 Ohio St.3d 150, 761 N.E.2d 18 (2002) (articulating Strickland two‑part test applied in Ohio)
Strickland v. Washington, 466 U.S. 668 (1984) (defendant must show deficient performance and a reasonable probability of a different result)