State v. Santiago-Dennis, 2014 Ohio 4204

Indictment: one count of assaulting a police officer at a Solon bus stop (Case CR-575190-A).
Incident occurred June 6, 2013; officers Cunningham and Petranic responded to a disturbance at the bus stop.
Defendant resisted arrest and engaged in flailing movements; officers attempted to subdue him.
Defendant’s hands struck Officer Cunningham during the altercation; Cunningham sustained finger injury.
Dash-cam audio captured defendant saying, “I am not resisting.”
Trial court denied the Rule 29 acquittal motion; defendant convicted of assault on a police officer; sentence included community control and restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence sufficed to prove the knowlingly caused harm element	State argued defendant knowingly caused or attempted harm to officer	Santiago-Dennis contends he was resisting arrest, not knowingly causing harm	Conviction reversed; insufficient proof of knowingly causing harm
Whether Rule 29 acquittal issue was properly considered given indictment	State treated as valid assault charge irrespective of resisting	Crim.R.29 should have been granted due to insufficient evidence	Second error deemed moot; conviction vacated on sufficiency grounds

State v. Curlee-Jones, 8th Dist. Cuyahoga No. 98233, 2013-Ohio-1175 (2013) (similar resisting-arrest scenario; no proven knowingly assault)
State v. Jackson, 8th Dist. Cuyahoga No. 97743, 2012-Ohio-4278 (2012) (knowingly element defined via surrounding facts)
State v. Dixon, 8th Dist. Cuyahoga No. 82951, 2004-Ohio-2406 (2004) (definition of knowingly under 2901.22(B))
State v. Huff, 145 Ohio App.3d 555, 763 N.E.2d 695 (2001) (interpretation of knowingly vs purposely)
State v. Givan, 8th Dist. Cuyahoga No. 94609, 2011-Ohio-100 (2011) (sufficiency review standard)
State v. Tenace, 109 Ohio St.3d 255, 847 N.E.2d 386 (2006) (sufficiency framework)
Cleveland v. Pate, 8th Dist. Cuyahoga No. 99321, 2013-Ohio-5571 (2013) (Crim.R.29 standard alignment)