State v. Stacy, 2023 Ohio 3942

Crystal Church obtained a domestic-relations protection order (Aug. 20, 2020) prohibiting Robert Stacy from entering her Hill Street residence and from contacting her; the order was effective through June 26, 2025.
On June 8, 2022, Church testified Stacy arrived at her front porch around 11:00 p.m., wearing a bookbag and asking to be let in; she refused and called the sheriff. Deputies found a bicycle in the driveway and a bookbag on the rear porch.
Stacy testified in his defense, denied the State’s version of events, and claimed he believed the protection order had been removed; he admitted prior violations (including a 2021 conviction for violating the order) and leaving a rose on Church’s porch in May 2022.
A jury convicted Stacy of one count of Violating a Protection Order (fifth-degree felony, R.C. 2919.27). The trial court sentenced him to 11 months in prison and, after two separate courtroom outbursts during sentencing, imposed two consecutive 30-day direct-contempt jail terms to run consecutively with the prison term.
Stacy appealed, raising (1) sufficiency and manifest-weight challenges to the conviction, and (2) claims that the 11-month sentence and the contempt findings/sanctions were improper or excessive.

Issue	State's Argument	Stacy's Argument	Held
Sufficiency of evidence to convict for violating protection order	Church’s testimony established Stacy was on her property in violation of a valid order	Stacy denied being present on June 8; no physical evidence ties him to bicycle/bookbag	Conviction supported; evidence sufficient when viewed in State’s favor
Recklessness as to the order’s existence (mental element)	Prior violations and lack of any court notice of removal show recklessness	Stacy reasonably believed the order had been removed	Rejection of Stacy’s belief as unreasonable; jury could find recklessness
Excessiveness of 11-month prison sentence	Sentence is within statutory range for an F5 and within trial court discretion	11 months is excessive	Affirmed: within statutory range and not contrary to law
Validity and length of two direct-contempt findings and consecutive 30-day terms	Stacy’s courtroom outbursts and noncooperation obstructed sentencing and justified summary contempt sanctions	Outbursts did not rise to obstruction; contempt/sanctions improper	Contempt findings and sanctions were not an abuse of discretion and were permissible; sentences fall within guiding limits

State v. Clinton, 153 Ohio St.3d 422 (Ohio 2017) (sufficiency standard review)
State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for reviewing sufficiency of the evidence)
State v. Wilson, 113 Ohio St.3d 382 (Ohio 2007) (distinguishes sufficiency and weight standards)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest-weight standard and "lost its way" test)
Windham Bank v. Tomaszczyk, 27 Ohio St.2d 55 (Ohio 1971) (definition and purpose of contempt proceedings)
State ex rel. Johnson v. Cty. Court of Perry Cty., 25 Ohio St.3d 53 (Ohio 1986) (summary punishment for direct contempt)
Disciplinary Counsel v. Repp, 165 Ohio St.3d 582 (Ohio 2021) (inherent authority to punish direct contempt summarily)
Disciplinary Counsel v. Bachman, 163 Ohio St.3d 195 (Ohio 2020) (direct-contempt requires imminent threat to administration of justice)
Brown v. United States, 356 U.S. 148 (U.S. 1958) (distinguishing offense-to-sensibilities from obstruction of justice)
State v. Bryant, 168 Ohio St.3d 250 (Ohio 2022) (court may punish disruptive courtroom outbursts as contempt)
State v. Kilbane, 61 Ohio St.2d 201 (Ohio 1980) (abuse-of-discretion standard for contempt review)
Denovchek v. Bd. of Trumbull Cty. Commrs., 36 Ohio St.3d 14 (Ohio 1988) (deference to trial court in contempt matters)
State ex rel. Yost v. Crossridge, Inc., 188 N.E.3d 629 (Ohio 2022) (R.C. 2705.05(A) sentencing limits function as a guidance for contempt sanctions)