State v. Plata, 2014 Ohio 449

Defendant Adrian Joel Plata appeals his convictions for grand theft of a motor vehicle, tampering with records, and falsification in Warren County Court of Common Pleas.
The state alleged Plata sold a 2001 Mazda Millenia to Michael Hodge, signed over the title, and then removed the vehicle after Hodge planned to transfer the title; a duplicate title was later obtained.
Hodge paid $1,450 for the car; the original title was signed but not notarized, and the vehicle was left at a Lebanon, Ohio location for repairs.
Plata obtained a duplicate title on October 9, 2012 by stating the original title had been lost; an investigation ensued after Hodge’s complaint and related Facebook posts.
The Mazda was later found in a barn; Plata was arrested October 12, 2012; the Bureau of Motor Vehicles issued the duplicate title the same day; Plata testified at trial and the jury found him guilty on all three counts.
Appellant challenges the sufficiency of the evidence for grand theft and the manifest-weight/sufficiency for the tampering with records and falsification convictions; the appellate court affirms the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for grand theft	Plata argues Hodge was not the owner.	Rhodes-like ownership not required; Plata owned the car.	Sufficient evidence to sustain.
Manifest weight and sufficiency for tampering with records and falsification	Ownership defense negates fraud elements.	Record-ownership not essential; false title application showed intent to defraud.	Convictions not against the manifest weight; evidence sufficient.

State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (establishes standard for mathematical sufficiency review of evidence)
State v. Rhodes, 2 Ohio St.3d 74 (Ohio 1982) (ownership for theft of a motor vehicle focuses on lawful possession, not title ownership)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency review standard for criminal convictions)