State v. Reynolds, 2021 Ohio 963

Defendant Ricky Reynolds was convicted in Hamilton County Municipal Court of domestic violence (R.C. 2919.25(A)) arising from an incident on October 31, 2019.
Victim Heather Reynolds testified Reynolds grabbed her by the neck, caused her to black out, hit her face, and stomped her leg between about 5:00 and 6:00 p.m.; police photographed injuries on November 4, 2019.
Defense introduced photos from October 30 showing a mark on Heather’s lip and argued the injury predated the alleged assault.
Reynolds presented an alibi: his son Tommy and brother Alan Philpot testified Reynolds was away from the apartment (together from ~4:00 to ~8:00 p.m.; waiting at Philpot’s driveway until ~7:00 p.m.).
The trial judge expressly found Heather credible, concluded the state proved guilt beyond a reasonable doubt, and convicted Reynolds.
Reynolds appealed, arguing (1) the court shifted the burden to him to prove his alibi and (2) the conviction was against the manifest weight of the evidence; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court shifted the burden of persuasion to defendant by its comments about the alibi	The State maintained the court properly assessed witness credibility and applied the beyond-a-reasonable-doubt standard	Reynolds argued the court’s remarks treated alibi as an affirmative defense and required him to "prove" it	Court held no burden shift; judge weighed credibility and explicitly found the State proved guilt beyond a reasonable doubt
Whether the conviction is against the manifest weight of the evidence	State argued evidence (victim testimony and photos) supported conviction and the judge reasonably found victim credible	Reynolds argued his alibi and prior photos undermined the State’s case	Court held conviction was not against the manifest weight; no miscarriage of justice and judge did not clearly lose its way

State v. Sorrels, 71 Ohio App.3d 162 (1st Dist.) (alibi is not an affirmative defense; any doubt from alibi goes to the State’s burden)
State v. Martin, 20 Ohio App.3d 172 (1st Dist.) (standard for manifest-weight review; reversal only in exceptional cases)