State v. Sternbach
2014 Ohio 4203
Ohio Ct. App.2014Background
- Defendant Jennifer Sternbach was convicted in a bench trial of two counts of aggravated assault and one count of child endangering.
- Case arose from a August 14, 2012 incident at a gas station captured on surveillance video.
- Butler and Owens were the alleged victims; Wells and Robinson were passengers in Sternbach’s gray car.
- Sternbach’s car interacted with the men who were arguing with Wells, leading to a collision and attempted chase.
- Trial court found evidence sufficient for aggravated assault defenses but this Court concluded otherwise and reversed/vacated the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated assault | Sternbach acted knowingly; used car as deadly weapon | Video shows accident, not knowing misconduct | Insufficient evidence; aggravated assault not proven beyond a reasonable doubt |
| Sufficiency of evidence for child endangering | Sternbach recklessly endangered child by driving | No evidence the child was placed in danger | Insufficient evidence; no reckless endangerment beyond reasonable doubt |
Key Cases Cited
- State v. McDuffie, 8th Dist. Cuyahoga No. 88662 (2007-Ohio-3421) (sufficiency standard; viewing evidence in light most favorable to prosecution)
- State v. Thompkins, — (—) (standard for sufficiency: rational juror could convict upon evidence presented)
- State v. Jenks, — (1991) (juror rationality and standard of review for sufficiency)
- State v. Huff, — (2006-Ohio-5081) (knowability of conduct from surrounding facts)
- State v. Tate, 8th Dist. Cuyahoga No. 87008 (2006-Ohio-3722) (car as deadly weapon when used to cause death or great bodily harm)
- State v. Copley, 8th Dist. Cuyahoga No. 92784 (2010-Ohio-2340) (no knowingly or deadly weapon usage shown; accident in fleeing)
- State v. Williams, 9th Dist. Medina No. 09CA0042-M (2010-Ohio-1248) (comparison for recklessness in endangerment)
- State v. Dover, 5th Dist. Stark No. 2007-CA-00140 (2008-Ohio-1071) (reckless endangerment standard in child endangering)
