State v. Patterson, 2021 Ohio 2387

Defendant Joshua Patterson was indicted on two counts of rape of a child under thirteen (one count alleging the victim was under ten). The offenses occurred before April 21, 2020.
Victim K.P.'s mother observed Patterson with his hand between K.P.'s legs and K.P. later told her mother Patterson "touched my pee pee." K.P. testified the touching occurred repeatedly when she was nine and ten and that Patterson put his finger "inside her crotch 'a little bit.'"
Patterson gave a recorded statement acknowledging he had touched K.P.'s vaginal area under her clothing multiple times and that K.P.'s vaginal lips may have come apart on some occasions.
At trial the court added anatomical definitions ("vulva," "labia," "labium") to the jury instructions over Patterson's objection; the jury convicted Patterson on both rape counts and the trial court imposed concurrent indefinite terms (15-to-life and 10-to-life).
On appeal Patterson challenged (1) sufficiency of the evidence (penetration and age), (2) manifest weight of the evidence, and (3) the propriety of the supplemental anatomical jury definitions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency — penetration element and victim's age for Count One	State: Victim testimony plus Patterson's admissions established penetration (finger caused labia to spread/entered "a little") and that at least one offense occurred when victim was under ten.	Patterson: Evidence did not prove penetration or that victim was under ten for Count One.	Court: Evidence sufficient on both penetration and age; convictions supported.
Manifest weight — whether verdict created a miscarriage of justice	State: Jury heard witnesses and evidence, credited testimony and statement, verdict should stand.	Patterson: Inconsistencies and vague evidence undermine verdict.	Court: Not an exceptional case; jury did not lose its way; weight of evidence supports convictions.
Jury instruction — inclusion of definitions for vulva/labia/labium	State: Definitions were accurate, consistent with common meaning, and warranted by the evidence of labia spreading.	Patterson: No medical evidence justified detailed anatomical definitions; definitions bolstered weak penetration proof.	Court: Definitions were legally correct, supported by evidence, and did not materially mislead or prejudice Patterson.

State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review: evidence taken in light most favorable to prosecution)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight standard; reversal only for exceptional cases where jury clearly lost its way)
State v. Wells, 91 Ohio St.3d 32 (2001) (use plain, ordinary meaning and dictionaries for statutory terms; interpret "cavity" v. "opening")
State v. Carpenter, 60 Ohio App.3d 104 (1989) (vaginal penetration can be shown by force sufficient to spread labia majora)
State v. Walker, 150 Ohio St.3d 409 (2016) (sufficiency of the evidence is a question of law for appellate review)
State v. Ketterer, 111 Ohio St.3d 70 (2006) (deference limits in sufficiency review; do not disturb verdict unless reasonable minds could not reach it)