State v. Roesener, 2022 Ohio 1901

On July 7, 2021, police responded after the victim reported that David R. Roesener struck her during an argument; Officer Schnarre arrested and charged Roesener with one count of first-degree misdemeanor domestic violence (R.C. 2919.25(A)).
Bench trial held November 15, 2021; trial court convicted and sentenced Roesener to 30 days (29 suspended) and three years community control.
Victim testified Roesener hit her on the left buttock during an argument, said it hurt at the time but was not serious, and did not believe Roesener intended to injure her or wish him convicted.
Officer Schnarre testified and introduced body-camera audio/video in which Roesener said he "patted her on the butt" and denied punching her; Schnarre characterized it as a "smack."
Trial court found both sides agreed a strike to the left buttock occurred, credited testimony that it caused pain, and found the elements of domestic violence satisfied.
Roesener appealed, arguing insufficient evidence of (1) physical harm and (2) that he knowingly caused or attempted to cause physical harm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence of physical harm?	Victim felt pain when struck; any injury, however brief, qualifies as physical harm under R.C. 2901.01(A)(3).	Pain was brief and minor; not enough to constitute actionable physical harm.	Yes. Court held brief pain suffices; duration and gravity irrelevant to the statutory definition of physical harm.
Was there sufficient evidence that defendant acted knowingly (intended or should have foreseen harm)?	Striking another with a closed fist is an act whose natural risk includes causing pain; defendant admitted striking her, so consequences were reasonably foreseeable.	Defendant characterized it as a light "pat" and lacked intent to injure.	Yes. Court concluded intent is shown by the act and its foreseeable risk; sufficiency review requires viewing evidence in the light most favorable to the State.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (explains appellate standard for sufficiency review: whether, viewing evidence in favor of prosecution, any rational trier of fact could find guilt beyond a reasonable doubt)