State v. Rodriguez, 2024 Ohio 5632

Jonathan Rodriguez was charged with two counts of fourth-degree misdemeanor domestic violence after threatening his stepfather, Luis Rodriguez Leiva, during a series of phone calls on November 11, 2023.
Leiva and Rodriguez's mother refused to lend Rodriguez a car, leading to repeated, angry phone calls including threats to kill Leiva.
Leiva, uncertain of Rodriguez's location and in fear, reported the threats to police and went to a police station.
During the bench trial, Rodriguez admitted making the threats and described his demeanor as angrier and more forceful than in any prior argument with Leiva.
The trial court acquitted Rodriguez on one count (from November 12, 2023) but convicted him for the November 11 threats, sentencing him to a suspended jail term, community control, and no contact with Leiva.
Rodriguez appealed, challenging the sufficiency and the manifest weight of the evidence for his conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence of imminent threat	State: Testimony and 911 call show reasonable fear	Rodriguez: Threat was remote, conditional, and not imminent due to distance	Sufficient evidence; conviction upheld
Manifest weight of the evidence	State: Leiva's reaction (police report) shows belief	Rodriguez: No history of violence, and parties separated by distance	Verdict not against manifest weight; conviction affirmed
Error in judgment entry (clerical error only)	N/A	N/A	Sentencing entry to be corrected to show bench trial

State v. Listo, 2010-Ohio-4408 (sufficiency of evidence review standard)
State v. Casey, 2024-Ohio-689 (victim’s belief of imminent harm is essential)
State v. Tackett, 2005-Ohio-1437 (definition of imminent harm in threat cases)
State v. Peyton, 2017-Ohio-243 (standard for reviewing sufficiency and manifest weight)
State v. Lunsford, 2011-Ohio-6529 (role of factfinder in credibility judgments)