Toledo v. Rainey, 2019 Ohio 4618

Appellant Dominick Rainey was a patient at Northwest Ohio Psychiatric Hospital and was charged with assault in Toledo Municipal Court; sentenced to 160 days.
On Oct. 20, 2018, therapeutic worker Carrie Mohler testified Rainey lunged from a doorway, struck a fellow patient (who was bleeding and unable to defend himself), then struck Mohler in the chest and a nurse in the arm while staff attempted to intervene.
Mohler testified Rainey had covered himself in Vaseline, looked her in the eye immediately before striking, and she suffered a chest contusion and weeks of pain; other staff provided first aid and assisted on scene.
Officer Reynolds arrived within minutes; Rainey allegedly told the officer he would continue to hit employees. Dr. Sirken prepared a same-day capacity assessment, noting taunting, laughing, Vaseline, and antisocial/violent propensity.
Rainey appealed, raising a single assignment of error: insufficient evidence to sustain the assault conviction (R.C. 2903.13(A)). The municipal conviction was affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict of assault	State: Mohler's eyewitness testimony, visible injuries, officer/doctor observations and Rainey's statements support knowing harm	Rainey: Only victim testified; lack of corroboration; alleged inconsistency between officer testimony and police report	Affirmed: Mohler's testimony and corroborating injury evidence were sufficient; corroboration not required; conviction upheld

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review: evidence must allow a rational trier of fact to find guilt beyond a reasonable doubt)
State v. Jenks, 61 Ohio St.3d 259 (Ohio standard for reviewing sufficiency of the evidence)
State v. Thompkins, 78 Ohio St.3d 380 (distinguishes sufficiency from manifest weight review)
State v. Beasley, 153 Ohio St.3d 497 (appellate role in evaluating sufficiency; do not weigh credibility)
State v. Walker, 55 Ohio St.2d 208 (appellate review limits)
State v. DeHass, 10 Ohio St.2d 230 (a single witness's testimony can support a conviction)