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Ohio Case Law

State v. Brown, 2025-Ohio-5603

Case Information

Court: Court of Appeals of Ohio Sixth Appellate District Lucas County
Date: 2025-12-16
Citation: 2025-Ohio-5603
Read the Opinion

Summary

Summary: The Court of Appeals of Ohio affirmed the domestic violence conviction of the appellant, finding sufficient and credible evidence that he knowingly caused physical harm to a household member. The case emphasizes that intent to harm is not a required element for a domestic violence conviction under Ohio law.

Key Holdings

  • Domestic violence under R.C. 2919.25(A) does not require proof of intent to harm only that the defendant knowingly caused or attempted to cause physical harm
  • A rational factfinder could conclude the appellant’s actions probably caused physical harm
  • The trial court’s judgment was not against the manifest weight of the evidence
  • The trial court had discretion to credit the victim’s version of events over the defendant’s
  • The appellate court affirmed the trial court’s judgment and sentence

More Information

The case arose from a alleged physical altercation between the appellant and a woman with whom he lived and had a relationship. On the night of the alleged incident, both parties were allegedly intoxicated and engaged in a violent confrontation that resulted in visible injuries. The woman claimed the appellant choked, struck, and attempted to strangle her during the confrontation, while the appellant claimed he acted in response to the woman’s drug-induced behavior and physical aggression. A police officer responding to calls for help observed signs of injury on both parties and arrested them.

Procedurally, the appellant was convicted in a bench trial in Toledo Municipal Court on charges of domestic violence and assault. The offenses were merged for sentencing, and the appellant was sentenced on the domestic violence charge to jail time (mostly suspended), probation, and continuation in a batterer’s program. He appealed the conviction, arguing it was not supported by sufficient evidence and was against the manifest weight of the evidence.

On appeal, the court rejected the appellant’s claims, holding that the offense of domestic violence requires that the defendant acted knowingly, not that he intended to harm. The court noted that the victim’s testimony, supported by photographic evidence of injuries, was sufficient to support the conviction. The court also found the trial court was entitled to credit the victim’s account over the appellant’s, despite both presenting differing narratives. The appellate court concluded that there was no miscarriage of justice and affirmed the conviction.