State v. Wilson, 2016 Ohio 7329

In Sept. 2015 L.W. called 911 reporting that Calvin Wilson (identified as her child’s father) assaulted her and threatened to shoot her; police observed bruises and scratches.
L.W. gave consistent oral statements to the 911 operator and a written statement at the scene identifying Wilson as the attacker (hit, punched, and kicked her).
Before trial L.W. executed an affidavit recanting and, at trial, testified for the defense giving a different account: she said Wilson did not touch her, denied he was the child’s father, and claimed someone else attacked her.
Officer testified he did not prompt L.W. to identify Wilson and that she completed the written statement in his presence; the 911 recording and written statement matched.
Wilson was charged with Domestic Violence (later amended) and Assault (R.C. 2903.13(A)). At a bench trial he was convicted of Assault, acquitted of Domestic Violence, and sentenced to one year basic supervised probation with fines and program requirements (90-day jail sentence suspended).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict of Assault (R.C. 2903.13(A))	State: 911 call, officer testimony, and written statement identify Wilson as the person who knowingly caused physical harm, satisfying elements.	Wilson: Victim’s multiple, inconsistent versions and recantation destroyed her credibility; testimony alone is insufficient.	Court: Evidence sufficient — 911 recording and written statement, supported by officer testimony, could allow a rational trier of fact to find guilt beyond a reasonable doubt.
Manifest weight / credibility of the victim’s testimony	State: Trial court could credit the victim’s initial statements and written statement over the recantation.	Wilson: Trial court erred because the victim’s changing accounts make conviction against manifest weight of evidence.	Court: No miscarriage of justice; factfinder entitled to assess credibility and could reasonably believe the initial statements.

State v. Thompkins, 78 Ohio St.3d 380 (1997) (explains manifest-weight standard and that appellate reversal is warranted only when jury clearly loses its way)
State v. Dennis, 79 Ohio St.3d 421 (1997) (frames sufficiency review under Jackson v. Virginia)
Jackson v. Virginia, 443 U.S. 307 (1979) (establishes standard for sufficiency of the evidence: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Antill, 176 Ohio St. 61 (1964) (trier of fact may credit some, part, or none of a witness’s testimony)
State v. DeHass, 10 Ohio St.2d 230 (1967) (credibility of witnesses is for the trier of fact)