State v. Szykulski, 2021 Ohio 2733

Defendant William T. Szykulski was charged with two counts of violating a civil stalking protection order under R.C. 2919.27 for (1) placing a card on his ex-girlfriend E.E.B.'s car windshield and (2) emailing E.E.B.'s employer.
A temporary civil stalking protection order (May 16, 2018) prohibited Szykulski from contacting E.E.B. or her employer and from coming within 500 feet.
E.E.B. testified she mailed the card to Szykulski in 2016, never retook possession, and found that same card on her windshield on July 31, 2018; she also identified the envelope and postmark.
E.E.B.'s supervisor received an email sent from an address identified as Szykulski's that referenced personal details and the protection-order proceedings; the email was forwarded to E.E.B. and then to prosecutors.
A jury convicted Szykulski on both counts; the municipal court imposed short jail terms (aggregating 6 days). Szykulski appealed, raising sufficiency and manifest-weight challenges to both convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency — card on windshield	Testimony and exhibit (card/envelope/postmark) show defendant had exclusive prior possession and thus placed card, satisfying elements	No direct proof: no photo, no surveillance, no forensic link; circumstantial evidence insufficient	Conviction upheld; circumstantial evidence and victim testimony sufficient to permit a rational trier of fact to find guilt beyond a reasonable doubt
Sufficiency — email to employer	Email header, sender ID, content tied to defendant, victim identification, and forwarding chain support authorship and sending	No forensic/email-server evidence proving authorship; circumstantial only	Conviction upheld; circumstantial evidence and witness ID sufficient
Manifest weight — card on windshield	Victim and officers credible; physical card/envelope corroborate account	Victim could have fabricated placement; lack of physical/forensic evidence undermines verdict	Conviction not against manifest weight; jury could reasonably credit victim and did not lose its way
Manifest weight — email to employer	Email provenance and witness identification credible; forwarding corroborates receipt by victim	Possible forgery or third-party sending; lack of forensic proof weakens weight	Conviction not against manifest weight; absence of forensic proof alone does not require reversal

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for sufficiency and review of criminal convictions)
State v. Tenace, 109 Ohio St.3d 255 (2006) (sufficiency review framework)
State v. Heinish, 50 Ohio St.3d 231 (1990) (circumstantial evidence may sustain conviction)
Tibbs v. Florida, 457 U.S. 31 (1982) (appellate weight-of-evidence review as thirteenth juror)
State v. DeHass, 10 Ohio St.3d 230 (syllabus rule on credibility determinations for trier of fact)
State v. Martin, 20 Ohio App.3d 172 (1st Dist.) (standard for reversing on manifest weight requires exceptional case)
State v. Antill, 176 Ohio St. 61 (1964) (jury may believe all, part, or none of witness testimony)