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2019 Ohio 4518
Ohio Ct. App.
2019
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Background

  • Defendant Jordan P. Singleton (son) was charged with one count of domestic violence for allegedly choking his mother during an argument in November 2018; the mother lived with him.
  • Victim testified Singleton put both hands around her neck, pushed her against a stair rail, and she saw visual symptoms; she photographed marks on her neck immediately after.
  • Less than nine minutes later she called 9-1-1 to report theft of gravel from her driveway; she initially did not report the assault on the call but told officers about it when they arrived.
  • Officer observed marks on the victim’s neck; Singleton admitted a verbal altercation but denied any physical assault.
  • After a bench trial, the court convicted Singleton of misdemeanor domestic violence (R.C. 2919.25(A)) and sentenced him January 11, 2019 to 180 days in jail and a $1,000 fine; the court later suspended 90 days of jail and the fine conditioned on a psychological evaluation and no law violations through January 11, 2020.
  • On appeal the court held the case was not moot (suspended-sentence condition remained), rejected arguments that evidence was insufficient or that the conviction was against the manifest weight of the evidence, affirmed the conviction, and remanded to correct a clerical error in the judgment entry.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Mootness (appeal) State: appeal not moot because suspended sentence conditions remain until Jan 11, 2020 Singleton: appeal moot because he served jail time and challenges conviction Not moot — suspended conditions leave collateral consequences possible until Jan 11, 2020
Sufficiency of the evidence (Crim.R. 29) State: photographic evidence, officer observation, victim testimony satisfy elements of R.C. 2919.25(A) Singleton: evidence was only he‑said/she‑said; police did not photograph injuries or sufficiently corroborate Evidence sufficient; reasonable minds could find guilt beyond a reasonable doubt
Manifest weight of the evidence State: trial court as factfinder reasonably credited victim and photographic evidence Singleton: conviction against weight because investigation gaps and inconsistent 9-1-1 call Not against manifest weight; court did not clearly lose its way in crediting victim and evidence

Key Cases Cited

  • State v. Golston, 71 Ohio St.3d 224 (1994) (voluntary satisfaction of sentence renders appeal moot absent collateral legal disability)
  • In re S.J.K., 114 Ohio St.3d 23 (2007) (collateral-consequences exception to mootness)
  • State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)
  • State v. Bridgeman, 55 Ohio St.2d 261 (1978) (sufficiency review—whether reasonable minds could find guilt)
  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight standard and limited role of appellate courts)
  • United States v. Collon, 426 F.2d 939 (6th Cir. 1970) (authority quoted for sufficiency formulation)
Read the full case

Case Details

Case Name: State v. Singleton
Court Name: Ohio Court of Appeals
Date Published: Nov 4, 2019
Citations: 2019 Ohio 4518; 2019-P-0013
Docket Number: 2019-P-0013
Court Abbreviation: Ohio Ct. App.
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