State v. Parish, 2014 Ohio 1410

Defendant Andrew S. Parish was charged with one count of domestic violence (R.C. 2919.25(A)) after an incident on Feb. 17, 2013 involving the mother of his child, Nakita Morgan.
Facts alleged: Parish pulled Morgan from her vehicle, slammed and choked her twice in front of her house; later poured liquor on her head, grabbed her hair, and struck her head against a refrigerator door; an eyewitness (Chelsi Early) intervened and police later spoke with Parish.
Morgan testified she and Parish were in a year‑and‑a‑half relationship, Parish was present at the child M.P.’s birth, and the child bears Parish’s surname; Morgan was married to an incarcerated man at M.P.’s birth.
Parish did not testify or present evidence at trial to dispute paternity or other testimony; jury found Parish guilty after a bench/trial proceeding and he was sentenced to 180 days with 90 suspended.
On appeal Parish argued his conviction was against the manifest weight and sufficiency of the evidence, principally contesting that Morgan was a “family or household member” because she was married to another man when the child was born and pointing to witness inconsistencies.
The appeals court reviewed both sufficiency (Jackson standard) and manifest‑weight principles and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to convict of domestic violence	State: testimony and eyewitness account proved Parish knowingly caused physical harm to a family/household member	Parish: evidence insufficient because Morgan was married to another man at child’s birth and testimony was inconsistent/false	Affirmed — viewing evidence in light most favorable to prosecution, a reasonable juror could find elements proven beyond a reasonable doubt
Whether conviction was against the manifest weight of the evidence	State: jury credited victim and eyewitness; inconsistencies go to credibility	Parish: inconsistencies and alleged false testimony defeat verdict; paternity not established	Affirmed — appellate court will not substitute its judgment for jury; no miscarriage of justice; credibility for jury to decide

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for constitutional sufficiency of the evidence)
McDaniel v. Brown, 558 U.S. 120 (U.S. 2010) (reaffirming Jackson sufficiency standard)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest‑weight standard and appellate role as thirteenth juror)
Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (Ohio 1984) (presumptions and reasonable intendments in reviewing weight of evidence)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (circumstantial evidence has same probative value as direct evidence)