State v. White, 2025 Ohio 306

Patricia Jo White was convicted by a jury of telecommunications harassment under R.C. 2917.21(A)(1) and/or (5) after sending repeated emails to Canton Police Officer Todd Gillilan and other public officials despite requests to stop.
The initial wave of emails began with allegations against Aultman Hospital regarding child trafficking; White continued contact after her July 2023 arrest, including emails with accusatory and threatening language.
White was only convicted with respect to emails sent after her July 2023 arrest and release, not for her emails sent prior.
She appealed her conviction, arguing insufficient evidence, that her speech was constitutionally protected, and that she received ineffective assistance of counsel.
The Court of Appeals affirmed the trial court, finding sufficient evidence of harassment, rejecting her First Amendment defense, and finding no ineffective assistance of counsel.

Issue	Appellant's Argument	State's Argument	Held
Sufficiency of evidence for harassment (purpose)	White’s emails were to voice concerns, not harass	The content showed intent to harass/intimidate	Sufficient evidence existed
Sufficiency: right to contact public official	Officer could not tell her to stop contacting him	Statute applies regardless of professional status	Statute properly applied
First Amendment protection	Emails about government matters are protected	Not prosecuted for content, but for harassment	Statute not unconstitutional
Ineffective assistance of counsel	Counsel failed to fully argue 1st Amend. at trial	No prejudice; claims had no likely merit	No ineffective assistance

State v. Jenks, 61 Ohio St.3d 259 (standard for reviewing sufficiency of evidence in criminal cases)
State v. Kronenberg, 2015-Ohio-1020 (R.C. 2917.21 does not restrict protected speech; overbreadth challenge to telecom harassment statute)
Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)