State v. Terry, 2021 Ohio 4043

Christopher Terry was subject to a Butler County civil protection order (R.C. 3113.31) prohibiting contact by telephone, with a limited exception for child-related communications via the "Our Family Wizard" app; Terry signed and received the order.
On Nov. 24, 2020, the victim (Wife) received a missed call and then a 13-second call from the number she recognized as Terry's; during the answered call she recognized Terry's voice and he yelled at her.
Wife captured screenshots of the incoming calls, presented them and the protection order to police, and Officer Clift filed criminal charges under R.C. 2919.27(A)(1).
At the bench trial Terry appeared pro se and argued he did not make the calls but was a victim of "caller ID spoofing;" he introduced his phone bill (showing no outgoing call at the alleged time), internet printouts about spoofing, and texts suggesting motive.
The trial court credited Wife's identification of Terry's number and voice, found Terry guilty of recklessly violating the protection order, and sentenced him to 180 days (165 suspended) with probation.
On appeal the Twelfth District reviewed sufficiency and manifest-weight challenges and affirmed, concluding the conviction was supported by sufficient evidence and not against the manifest weight.

Issue	State's Argument	Terry's Argument	Held
Whether evidence was sufficient and conviction not against manifest weight for violating a protection order by telephone contact	Screenshots, Wife's recognition of the number and voice, and protective order satisfy element of reckless contact in violation of R.C. 2919.27(A)(1)	Caller-ID spoofing could explain incoming call and phone bill shows no outgoing call; therefore reasonable doubt exists	Affirmed: trial court credited Wife's testimony and identification; evidence supports conviction and does not weigh heavily in favor of acquittal

State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishing legal sufficiency from manifest weight and explaining standards for each)