State v. Vaughan, 2017 Ohio 583

Defendant Robert Vaughan was indicted on two counts of endangering children for injuries to his infant daughter: (1) reckless abuse (R.C. 2919.22(B)(1)) and (2) creating a substantial risk by violating a duty of care (R.C. 2919.22(A)); both counts included a serious-physical-harm finding.
Medical exams revealed multiple cuts/bruises, a broken leg (earlier incident) and three broken ribs; pediatrician testified rib fractures require significant focal force and cause substantial pain.
The mother (I.B.) testified Vaughan was the primary caregiver at times, described incidents where Vaughan admitted rough handling (squeezing under the ribs, dropping/bouncing the child), and said she believed Vaughan caused the rib fractures; she previously failed to obtain timely treatment in some instances.
Vaughan gave inconsistent statements: initially blamed accidents (a baby-wipe lid, hitting stairs) and later admitted lying to protect the family; he also acknowledged dropping the child "a couple of times" and that his grip might have been strong enough to injure ribs.
The jury convicted on both counts, the trial court merged the counts and sentenced Vaughan to three years on the abuse-with-serious-harm (second-degree felony) count; Vaughan appealed arguing insufficiency and manifest-weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to convict Vaughan of child endangering by abuse causing serious physical harm	State: medical proof of broken ribs/leg and injuries plus testimony placing Vaughan as caregiver permit a finding that Vaughan recklessly abused the child	Vaughan: State failed to prove he caused the injuries or the timing; medical testimony did not attribute injuries to his acts	Affirmed — evidence was sufficient when viewed in the light most favorable to prosecution
Whether convictions were against the manifest weight of the evidence	State: jury reasonably credited medical and witness testimony and inferences supporting abuse	Vaughan: conflicting explanations and lack of direct proof that he caused injuries make verdicts against manifest weight	Affirmed — appellate court finds jury did not lose its way; verdict supported by competent, credible evidence

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency standard viewing evidence in light most favorable to prosecution)
McDaniel v. Brown, 558 U.S. 120 (reaffirms Jackson sufficiency standard)
State v. Fry, 926 N.E.2d 1239 (Ohio 2010) (citing standards for sufficiency review)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (defines manifest-weight review and reversal standard)
Seasons Coal Co., Inc. v. Cleveland, 461 N.E.2d 1273 (Ohio 1984) (presumption in favor of trial court findings on weight)
State v. Jenks, 574 N.E.2d 492 (Ohio 1991) (circumstantial evidence and its probative value equal to direct evidence)
State v. O'Brien, 508 N.E.2d 144 (Ohio 1987) (recklessness as culpable mental state for child endangering)
Eastley v. Volkman, 972 N.E.2d 517 (Ohio 2012) (deference to trial court factfinding on weight of evidence)
State v. Lott, 555 N.E.2d 293 (Ohio) (permissible inferential reasoning from facts)