State v. Parker, 2021 Ohio 3422

Kenneth Parker (aka multiple names) is the father of a child born in 2016 and was indicted in October 2019 for one count of nonsupport of a dependent under R.C. 2919.21 (alleged 26 weeks of nonpayment out of 104 consecutive weeks between Feb–Oct 2019).
Parker proceeded pro se, filing multiple pretrial motions including a motion to dismiss and a Crim.R. 29 motion for judgment of acquittal; the court denied the pretrial dismissal motion as premature and did not issue a written ruling on the Crim.R. 29 motion before trial.
After a multi-day jury trial, Parker was convicted; the trial court sentenced him to three years of community control and ordered payment of a child-support arrearage of $25,665.67.
On appeal Parker raised seven assignments of error (sufficiency/Crim.R.29 denial; admission of an administrative child-support order; discovery/production requests; exclusion of a proposed witness; constitutional objections re: Ohio law and FCCSEA). He filed only a 19‑page excerpt of the trial transcript (voir dire of one witness), not a complete transcript.
The appellate court affirmed the conviction, emphasizing that the appellant bears the burden to provide the trial record for review, presuming regularity where transcript portions necessary for review are omitted; the court also reviewed and rejected the merits of Parker’s claims where it had an adequate basis to do so.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of Crim.R.29 motion / sufficiency of evidence	State: evidence sufficient to submit to jury	Parker: evidence insufficient; trial court should have granted acquittal	Affirmed; no transcript to review sufficiency; motions pretrial cannot obtain summary judgment; assignment overruled
Admission of administrative child-support order	State: order admissible; trial court within discretion to admit	Parker: administrative order should not have been admitted	Affirmed; absent transcript, court presumes trial court acted properly and no abuse of discretion shown
Requests for disclosure / sufficiency of State’s proof	State: complied with discovery and presented sufficient proof	Parker: trial court erred by denying disclosure of contracts/documents and by failing to require prima facie proof	Affirmed; appellant failed to supply record to evaluate these sufficiency/discovery claims
Exclusion of proffered witness (Jackson)	State: trial court has discretion to admit/exclude expert/witness testimony	Parker: proposed witness (credit-report expert) was improperly excluded and prejudiced defense	Affirmed; transcript excerpt shows voir dire only, no ruling in record, so no basis to find abuse of discretion

Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (1980) (appellant bears burden of showing error by reference to record; missing transcript leads to presumption of regularity)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency: after viewing evidence in light most favorable to prosecution, any rational trier of fact could find elements proved)
State v. Robinson, 124 Ohio St.3d 76 (2009) (applies Jenks sufficiency standard)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard defined)
State v. Robb, 88 Ohio St.3d 59 (2000) (admission/exclusion of relevant evidence rests within trial court discretion)
State v. Sage, 31 Ohio St.3d 173 (1987) (same: appellate review limited absent abuse and prejudice)
State v. Adams, 62 Ohio St.2d 151 (1980) (abuse of discretion implies unreasonable or arbitrary conduct)
State v. Tipton, 135 Ohio App.3d 227 (1999) (criminal rules do not permit pretrial summary-judgment style disposition on an indictment)