State v. Snyder, 192 Ohio App. 3d 55

Snyder was observed inside an enclosed porch at 3:30 a.m. on August 28, 2009.
Eldridge called 911 after seeing Snyder and noted the back door knob turning but door remained locked.
Snyder was arrested in the driveway; Eldridge identified him as the intruder.
Snyder was charged with burglary under R.C. 2911.12(A)(1) with a repeat-violent-offender specification (later dismissed).
At trial, jury verdict found Snyder guilty of burglary under R.C. 2911.12(A)(4); sentence was 18 months.
The trial court instructed on both versions of burglary; definitions for A1 were provided, but A4 definitions were limited.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plain-error burden in burglary instructions	Snyder argues the A1/A4 distinction was misdescribed.	Snyder contends failure to define key terms prejudiced the verdict.	First assignment overruled; no plain error.
Sufficiency of evidence for burglary A4	State failed to prove force or presence of others.	State satisfied force entry and habitation presence.	Conviction under A4 sustained; sufficient evidence shown.
Duty to instruct on criminal trespass as lesser offense	Trial court should have given criminal-trespass instruction.	Lesser-included instruction not mandatory when evidence supports burglary.	Second assignment overruled; no error requiring trespass instruction.

State v. Adams, 62 Ohio St.2d 151 (1980) (plain-error review for jury instruction sufficiency; not per se reversible)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review; credibility not weighed on appeal)
State v. Carter, 89 Ohio St.3d 593 (2000) (when lesser-included offense instruction is required)
State v. Lane, 50 Ohio App.2d 41 (1976) (force element satisfied by entry through closed but unlocked door)