State v. Watson, 2018 Ohio 4964

Defendant Brandon D. Watson was indicted for one count of felonious assault (R.C. 2903.11) for a single unprovoked, closed-fist punch to Richard Grieshop’s head on March 21, 2017.
Incident witnessed by a bystander who identified Watson as the assailant; victim was knocked unconscious and later hospitalized.
Victim sustained a traumatic brain injury, fractured skull, internal bleeding, multiple seizures, and memory problems; loss of consciousness and those injuries qualified as serious physical harm.
Watson waived a jury and was tried before the court; the trial court denied his Crim.R. 29 motion for acquittal and found him guilty.
The trial court sentenced Watson to five years’ imprisonment; Watson appealed arguing insufficiency of the evidence and erroneous denial of his Crim.R. 29 motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Watson knowingly caused serious physical harm (felonious assault) and whether denial of Crim.R. 29 was erroneous	State: single, unprovoked, forceful blindside punch that rendered victim unconscious and produced severe injuries satisfied the elements; credibility resolved for the trier of fact	Watson: single punch by a non-fighter against a similarly sized victim is insufficient to show the requisite knowledge that serious physical harm would probably result (relies on McFadden)	Affirmed: evidence, viewed in the light most favorable to the State, was sufficient to show Watson acted knowingly and caused serious physical harm; Crim.R. 29 denial proper

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for sufficiency review and appellate role in weighing evidence)
State v. Tenace, 109 Ohio St.3d 255 (2006) (explains sufficiency standard: whether any rational trier of fact could find elements proven beyond a reasonable doubt)