State v. Nettles, 2019 Ohio 3682

Joshua Nettles and Erica Jackson share a four-year-old son; on May 15, 2018 Jackson brought the child to Nettles’s parents’ home for a weekend visit where a yard altercation occurred.
Jackson testified Nettles grabbed her by the throat, slammed her to the ground, stomped and kicked her in the face, and instructed his girlfriend Shawnay Glover to get on top of and beat Jackson; Jackson fled with the child and called 911.
Officer Pitts found Jackson a few blocks away with bruises, cuts, and markings on her throat and chest, photographed her injuries, and recorded her account implicating Nettles.
Eyewitness accounts conflicted: neighbor Karen Caldwell originally told police she saw Nettles kick Jackson but at trial recanted; witness Beecher’s trial testimony contradicted his statement to police and the trial court found him not credible.
The municipal court credited Jackson and Pitts, discredited Caldwell and Beecher, convicted Nettles of assault (R.C. 2903.13(A)), acquitted him of domestic violence, and sentenced him to 90 days’ incarceration.
Nettles appealed, raising two assignments of error: conviction was against the manifest weight of the evidence, and the trial court improperly limited cross-examination; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction was against the manifest weight of the evidence	State: Jackson’s testimony, Pitts’s observations and photographs corroborate a knowing infliction of physical harm by Nettles.	Nettles: Glover, not Nettles, caused injuries; Jackson’s account is inconsistent or impossible and injuries exaggerated.	Affirmed — trial court reasonably credited Jackson and Pitts; appellate court will not substitute its judgment for trial court credibility findings.
Whether the trial court improperly limited cross-examination of Jackson	State: The question about police charging decisions was irrelevant and duplicative; court properly exercised discretion.	Nettles: Limitation prevented eliciting Jackson’s role in provoking the fight and prior aggression, prejudicing defense.	Affirmed — court did not abuse discretion; the question was duplicative, defense did not proffer further inquiry.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (sets manifest-weight-of-the-evidence standard)
Tibbs v. Florida, 457 U.S. 31 (1982) (appellate court as a "thirteenth juror" when reviewing weight claims)
State v. DeHass, 10 Ohio St.2d 230 (1967) (deference to factfinder on witness credibility)
State v. Green, 66 Ohio St.3d 141 (1993) (trial court discretion to limit cross-examination)
Alford v. United States, 282 U.S. 687 (1931) (extent of cross-examination is within trial court's discretion)
State v. Martin, 20 Ohio App.3d 172 (1983) (manifest-weight reversal reserved for exceptional cases)