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State v. Parker
2022 Ohio 1237
| Ohio Ct. App. | 2022
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Background

  • Anthony Parker confronted two strangers walking home from a convenience store and demanded return of two 24‑oz beers; a struggle followed and one victim was pushed to the ground.
  • Security‑camera footage captured the altercation; one victim reported a minor finger injury and the other retrieved her 12‑pack and ran to a nearby apartment building.
  • Parker admitted recent heavy alcohol consumption; an officer found him incoherent and had him taken to a hospital for evaluation.
  • Parker testified he had purchased the two cans himself and simply retrieved them after the victims placed them in a cart; he claimed any force was incidental to reclaiming his property.
  • A bench trial convicted Parker of two counts of third‑degree robbery under R.C. 2911.02(A)(3); he received concurrent community‑control terms and appealed, challenging sufficiency and weight of the evidence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was there legally sufficient evidence to convict Parker of robbery under R.C. 2911.02(A)(3)? The state argued the video, victim testimony, and circumstances established Parker used force or threatened force in committing a theft. Parker contended the evidence was insufficient because victims may have stolen his beer and no receipts were produced. Affirmed: viewing evidence in the light most favorable to the prosecution, a rational trier of fact could find all elements proven beyond a reasonable doubt.
Was the verdict against the manifest weight of the evidence (credibility/justification defense)? The state argued victim testimony and video were credible; court should defer to factfinder on credibility. Parker argued victims were unreliable, motivated to avoid prosecution, and his force was justified to recover his property. Affirmed: the court found the factfinder did not lose its way; Parker’s testimony conflicted with video and was not persuasive enough to warrant a new trial.

Key Cases Cited

  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and weight‑of‑evidence standards)
  • State v. Jenks, 61 Ohio St.3d 259 (1991) (sets Jackson/Jenks standard for legal sufficiency review)
  • State v. Drummond, 111 Ohio St.3d 14 (2006) (explains broader weight‑of‑evidence review)
  • State v. Wilson, 113 Ohio St.3d 382 (2007) (contrasts sufficiency and weight and discusses appellate review deference to factfinder)
  • State v. Martin, 20 Ohio App.3d 172 (1984) (articulates standard for granting a new trial when verdict is against manifest weight of evidence)
Read the full case

Case Details

Case Name: State v. Parker
Court Name: Ohio Court of Appeals
Date Published: Apr 14, 2022
Citation: 2022 Ohio 1237
Docket Number: 110716
Court Abbreviation: Ohio Ct. App.