State v. Stevenson, 2016 Ohio 321

In early September, nine-year-old A.S. was found in a neighbor's yard barefoot, without a coat, crying, and with a bruised/swollen left eye; her mother (N.C.) called police.
Dayton police and medical personnel documented bruises to A.S.’s eye, armpits, and a scratch on her back; photographs were taken at the hospital.
Wesley Stevenson, A.S.’s father, was charged in juvenile court with one count of Child Endangering (R.C. 2919.22(B)(1)).
At a bench trial A.S. testified that Stevenson grabbed her, accused her of stealing his phone, and hit/punched her; Stevenson denied punching her, admitted grabbing her shirt and yelling, and claimed he intended only reasonable corporal punishment.
The juvenile court found Stevenson guilty, sentenced him to 180 days (168 suspended) with nine days to be served on weekends, and he appealed arguing the conviction was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conviction was against the manifest weight of the evidence	State: victim, neighbor, and officer testimony and medical photos corroborate injuries and support conviction	Stevenson: victim’s testimony was inconsistent; his testimony showed only reasonable corporal punishment and the court ignored his account	Court affirmed: trier of fact credited State’s witnesses, found discrepancies minor, and concluded conduct was abuse not reasonable punishment

State v. Thompkins, 78 Ohio St.3d 380 (1997) (defines manifest-weight review and standard for reversal)
State v. Martin, 20 Ohio App.3d 172 (1983) (cases should be reversed on manifest-weight grounds only in exceptional situations)
Seasons Coal Co., Inc. v. Cleveland, 10 Ohio St.3d 77 (1984) (trier of fact best positioned to assess witness credibility)