State v. Noah, 2022 Ohio 1315

Defendant Joseph R. Noah and codefendant David Antio were indicted for second-degree felonious assault based on an unprovoked attack in a bar parking lot.
Surveillance video showed Noah and Antio pushing, punching, kicking, and dragging victim David Asmondy between parked vehicles.
Police photographs documented facial redness and abrasions to Asmondy’s jaw, neck, chest, and shoulder; medical records showed a fractured nose and concussion; Asmondy testified to headaches, breathing and vision problems, and physical therapy.
The jury convicted Noah of felonious assault; the trial court imposed 18 months of community-control sanctions, including eight weekends in jail.
On appeal Noah’s sole assignment of error challenged the sufficiency of the evidence, arguing the state failed to prove the statutory element of “serious physical harm.”

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove "serious physical harm" under R.C. 2901.01(A)(5)	State: video, photos, medical records, and testimony established a fractured nose, concussion, and substantial/acute pain — meeting the statutory definition	Noah: medical records inconsistent; injuries not severe enough to constitute "serious physical harm"; prosecution mischaracterized injuries	Court: Evidence viewed in the light most favorable to the prosecution was sufficient; a broken nose and concussion support "serious physical harm."

State v. Murphy, 91 Ohio St.3d 516 (explaining appellate sufficiency review)
State v. Walker, 150 Ohio St.3d 409 (reaffirming the standard that evidence must permit a rational trier of fact to find guilt beyond a reasonable doubt)
State v. Jenks, 61 Ohio St.3d 259 (establishing the appellate sufficiency test)
State v. Daniels, 14 Ohio App.3d 41 (broken nose can constitute serious physical harm)