State v. Vandergriff, 2021 Ohio 3230

At Dollar Tree, Vicky Vandergriff became verbally abusive toward cashiers and threatened one with her crutch; a bystander, John Neidich, intervened and exchanged words with Vandergriff.
The confrontation escalated into a physical altercation outside the store: Neidich testified Vandergriff struck him with a crutch, bit him under the arm, and, with others, punched and tore his shirt; deputies observed injuries and torn clothing.
Vandergriff testified she acted in self-defense, alleging Neidich first shoved/punched her wife and then struck her.
All three women involved were charged with misdemeanor assault; Vandergriff and codefendant Heaven Albright were tried together in a bench trial.
The trial court credited Neidich and the deputies, found Vandergriff guilty (Albright not guilty), and sentenced Vandergriff to 180 days (179 suspended).
Vandergriff appealed, advancing three assignments: (1) due process violation for failing to obtain/store surveillance video, (2) conviction against the manifest weight of the evidence, and (3) insufficient evidence because the state failed to disprove her self-defense claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court violate due process by not obtaining surveillance video?	State: Court offered continuance; defendants chose to proceed, so no due process violation.	Vandergriff: Court erred by deferring to her choice and failing to require video production.	Held: Invited error — Vandergriff waived complaint by electing to proceed; assignment overruled.
Was the conviction against the manifest weight of the evidence?	State: Credible testimony from Neidich and deputies supported conviction; credibility for trier of fact.	Vandergriff: Trial court miscredited evidence; conviction a miscarriage of justice.	Held: No manifest miscarriage; court did not lose its way; assignment overruled.
Was the evidence insufficient because self-defense was not disproven?	State: Viewing evidence in the light most favorable to the prosecution, a rational trier could find Vandergriff did not act in self-defense.	Vandergriff: Presented self-defense evidence; prosecution failed to disprove beyond a reasonable doubt.	Held: Sufficiency met; conviction supported; assignment overruled.

State v. Ford, 158 Ohio St.3d 139 (invited-error doctrine bars claiming an error the party invited)
Hal Artz Lincoln-Mercury, Inc. v. Ford Motor Co., 28 Ohio St.3d 20 (party may not take advantage of an error it induced)
State v. Campbell, 90 Ohio St.3d 320 (invited-error requires more than mere acquiescence; examples where party requested procedure)
Carrothers v. Hunter, 23 Ohio St.2d 99 (invited-error principle)
State v. Wigglesworth, 18 Ohio St.2d 171 (invited-error precedent)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard; appellate "thirteenth juror")
State v. Martin, 20 Ohio App.3d 172 (framework for reversing for manifest miscarriage of justice)
State v. Walker, 150 Ohio St.3d 409 (sufficiency review and application of Jenks standard)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency standard: view evidence in light most favorable to prosecution)
State v. Ellison, 178 Ohio App.3d 734 (sufficiency review is a de novo legal question)