State v. Robinson, 2014 Ohio 520

Defendant William L. Robinson convicted by a jury of aggravated burglary and sexual battery arising from an incident in A.C.’s apartment.
DNA (semen) matched Robinson; Robinson admitted sexual activity but claimed it was consensual and that A.C. invited him over while she was high.
Physical evidence (dirt on a chair under an open window, apparent handprints on a couch cushion) suggested entry through an open window by boosting/climbing in.
A.C. testified she was awakened by someone performing oral sex, screamed, and the assailant fled after a struggle with her boyfriend.
Trial court imposed consecutive prison terms for the two convictions; Robinson appealed arguing (1) verdicts were against the manifest weight of the evidence and (2) the court failed to make required findings for consecutive sentences under R.C. 2929.14(C)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether convictions were supported by the manifest weight/sufficiency of the evidence	State: Physical evidence + victim testimony + DNA support burglary and sexual battery; jury properly credited victim	Robinson: Sex was consensual; he was invited in and A.C. was high, so jury should have doubted guilt	Court: Evidence sufficient; jury reasonably credited victim and physical evidence contradicted Robinson; assignment overruled
Whether trial court made required findings for consecutive sentences under R.C. 2929.14(C)	State: Trial judge articulated purposes/principles and specific reasons, satisfying statutory requirements	Robinson: Court failed to make the necessary statutory findings on the record for consecutive terms	Court: Judge’s on-the-record statements (harm, prior record, seriousness, protection/punishment) satisfied R.C. 2929.14(C); assignment overruled

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency from manifest-weight standards)
State v. Jenks, 61 Ohio St.3d 259 (1991) (Jackson standard for sufficiency review adopted in Ohio)
Jackson v. Virginia, 443 U.S. 307 (1979) (legal sufficiency: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Martin, 20 Ohio App.3d 172 (1983) (appellate court as "thirteenth juror" in weight review)
State v. DeHass, 10 Ohio St.2d 230 (1967) (jury may consider inconsistencies in witness testimony)
Columbus v. Henry, 105 Ohio App.3d 545 (10th Dist. 1995) (discussion of manifest-weight review)
State v. Harris, 73 Ohio App.3d 57 (10th Dist. 1991) (credibility doubts do not automatically render verdict against manifest weight)
State v. Lakes, 120 Ohio App. 213 (4th Dist. 1964) (province of jury to resolve conflicting statements)