2019 Ohio 3201
Ohio Ct. App.2019Background
- On Nov. 16, 2017, an altercation occurred between defendant Lachashia Price and her half‑sister Tieya Price; charges were filed for domestic violence, assault, and criminal damaging.
- Trial was a bench trial on June 7, 2018; the court found Price guilty of domestic violence and criminal damaging (assault merged into domestic violence).
- Witnesses Tieya and her daughter Lamya Demmons testified Price struck Tieya in the face with a rearview mirror and with her fist and kicked Tieya’s vehicle; police photographs and officers observed injury and blood.
- Price and her boyfriend Jermain Talie testified Tieya had been intoxicated, instigated the fight, and Price struck Tieya in self‑defense; they left before speaking with officers.
- The court sentenced Price to 180 days jail (suspended), five years community control (first year supervised probation, then modified to non‑reporting), restitution, a $50 fine, and court costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for domestic violence | State: testimony and photos show Price knowingly caused physical harm to a household member | Price: testimony of Tieya and Demmons not credible; credible evidence supports self‑defense | Court: Evidence sufficient; a rational trier of fact could find elements proven beyond reasonable doubt |
| Manifest weight of the evidence | State: factfinder properly credited victim and daughter; injuries corroborated | Price: trial court lost its way by crediting inconsistent or intoxicated witnesses; verdict against manifest weight | Court: Trial court did not clearly lose its way; credibility determinations deferred to factfinder; conviction not against manifest weight |
Key Cases Cited
- State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (1991) (standard for sufficiency of the evidence review)
- State v. DeHass, 10 Ohio St.2d 230, 227 N.E.2d 212 (1967) (factfinder credibility determinations given deference)
- State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (1983) (standard for granting new trial on manifest weight grounds)