State v. Richards, 2022 Ohio 4698

Christopher Richards was charged in two municipal-court complaints with first-degree-misdemeanor child endangerment for allegedly overdosing and being unable to care for his children (ages three and five).
Neighbor Denise Hall found Richards’ wife and Richards unresponsive; one of the young children answered the apartment door crying that “Daddy was sleeping.”
Officer Teeple found Richards unresponsive between the bed and the wall; paramedics administered Narcan, which produced a limited response; Richards was later agitated, sedated, and taken to the hospital.
At bench trial, the prosecutor elected which complaint corresponded to which child; the court convicted Richards on the A-count (which named three-year-old P.R.) and acquitted on the B-count.
The court acknowledged no drugs or paraphernalia were found but relied on Richards’ unresponsiveness, position, difficulty waking him, and Narcan’s effect to find he had been incapacitated and recklessly created a substantial risk to the child.
Richards was sentenced to 180 days with 180 suspended, one year community control with drug screens and child-services cooperation, and he appealed challenging sufficiency and manifest weight.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency — identity/element of victim	State: evidence showed Richards was incapacitated while a child was present, supporting conviction.	Richards: prosecution elected the wrong child; Hall’s testimony identified “the baby,” creating doubt which undermines sufficiency.	Identity of the specific child named is not an element of R.C. 2919.22(A); evidence supported that Richards endangered a child under 18; sufficiency upheld.
Manifest weight — recklessness/inference of overdose	State: Richards’ unconsciousness until Narcan and the child’s distress show reckless disregard and substantial risk.	Richards: inference of opioid overdose and recklessness against weight—no drugs found; Narcan response and positioning disputed.	Trial court’s inferences (position, inability to wake, Narcan response, child distressed) were reasonable; court did not clearly lose its way; conviction affirmed.

State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (standards for sufficiency review)
Jackson v. Virginia, 443 U.S. 307 (standard for determining whether evidence supports conviction)
State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (manifest-weight-review framework)
State v. Jones, 166 Ohio St.3d 85, 182 N.E.3d 1161 (deference to factfinder on credibility/inferences)
State v. McFarland, 162 Ohio St.3d 36, 164 N.E.3d 316 (discussion of resolving testimonial conflicts)
State v. Bush, 152 N.E.3d 892 (recklessness mental state in child-endangerment context)
State v. Randolph, 194 N.E.3d 476 (victim-identification not required where not element of offense)
State v. Woullard, 158 Ohio App.3d 31, 813 N.E.2d 964 (respecting factfinder’s credibility determinations)
State v. Martin, 20 Ohio App.3d 172, 485 N.E.2d 717 (reversal on manifest weight only in exceptional cases)