State v. Sipple, 170 N.E.3d 1273

At a community event, Lawrence Sipple approached Melvina Chestnut from behind, whispered that she was "free-ballin," and (according to Chestnut) placed his phone between her legs under her dress; she felt the phone, saw a black screen, and did not hear or see a photo taken.
Officer Mathews’ body‑cam recorded Sipple admitting he put his phone under Chestnut’s dress but denying he took pictures; Sipple said he was "joking" and offered to show his phone.
Sipple was charged with voyeurism but convicted after a bench trial of attempted voyeurism under R.C. 2907.08(D).
At sentencing the court classified Sipple as a Tier I sex offender, informed him of registration duties at the hearing, and the journal entry said "register tier I" but did not recite a statutory summary and duration of registration duties.
Sipple appealed claiming (1) insufficient evidence / manifest weight error as to attempted voyeurism, and (2) the sentencing entry failed to include the required summary/duration for Tier I registration, rendering the classification invalid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency/manifest weight: did Sipple take a "substantial step" and act "surreptitiously" toward voyeurism?	State: placing a phone under Chestnut’s dress without her consent was surreptitious and a substantial step toward recording; actual capture of a photo/video not required for attempt.	Sipple: Chestnut saw him and saw a black screen so act was not surreptitious; no evidence phone was in camera mode or that any photo/video existed—mere preparation.	Affirmed conviction: court found placement was stealthy and unauthorized, and the act strongly corroborated the intent to record—satisfies substantial‑step standard.
Sentencing entry: did omission of a statutory summary/duration from the journal entry void Tier I classification?	State: Tier designation in the journal entry plus oral advisement at sentencing and the statutorily required notification form satisfies R.C. 2929.23(B); tier inclusion is the operative sanction.	Sipple: omission of the statutory summary and duration from the sentencing entry renders the classification void.	Affirmed classification: court held including "register tier I" in the entry and informing the defendant at sentencing (and providing the form) satisfied the statute; the Tier I classification stands.

State v. Woods, 48 Ohio St.2d 127, 357 N.E.2d 1059 (Ohio 1976) (adopts Model Penal Code "substantial step" test for attempt).
State v. Brooks, 44 Ohio St.3d 185, 542 N.E.2d 636 (Ohio 1989) (pointing a weapon alone insufficient for attempt absent corroborating evidence of intent).
State v. Group, 98 Ohio St.3d 248, 781 N.E.2d 980 (Ohio 2002) (discusses attempt and substantial‑step requirements).
State v. Williams, 129 Ohio St.3d 344, 952 N.E.2d 1108 (Ohio 2011) (AWA tiering and registration requirements are punitive and automatic based on conviction).
Middletown v. Reuss, 48 N.E.3d 649 (Ohio Ct. App.) (Twelfth Dist.) (held evidence insufficient where holding phone over partition lacked corroborating acts; discussed by majority and dissent).
State v. Halsey, 74 N.E.3d 915 (Ohio Ct. App.) (discusses requirement that tier classification be included in sentencing entry).