insufficient evidence claim (Ohio) · Go Syfert
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insufficient evidence claim in Ohio

12 Ohio opinions name it 1 courts 1999–2026 4 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
State v. McKinneygreen
ohioctapp · 2024 · cited in 3 Ohio opinions naming this issue, 2025–2026
2 sentences

2026See In re C.N., 2015-Ohio-2546, ¶ 9 (10th Dist.) (“though sufficiency and manifest weight are different legal concepts, a finding that a judgment is supported by the manifest weight of the evidence necessarily includes a finding that sufficient evidence supports the judgment”); see also State v. McKinney, 2024-Ohio-4642, ¶ 63 (4th Dist.) (“a determination that the weight of the evidence supports a conviction also is dispositive of an insufficient-evidence claim”).

2026See In re C.N., 2015-Ohio-2546 , ¶ 9 (10th Dist.) (“though sufficiency and manifest weight are different legal concepts, a finding that a judgment is supported by the manifest weight of the evidence necessarily includes a finding that sufficient HIGHLAND, 25CA12 22 evidence supports the judgment”); see also State v. McKinney, 2024-Ohio-4642, ¶ 63 (4th Dist.) (“a determination that the weight of the evidence supports a conviction also is dispositive of an insufficient-evidence claim”).

33
State v. Bengegreen
ohio · 1996 · cited in 3 Ohio opinions naming this issue, 2006–2015
2 sentences

2015State v. Benge, 75 Ohio St.3d 136, 143 , 1996-Ohio-227 . {¶ 7} Eldridge was convicted of OVI in violation of R.C. 4511.19(A)(1)(a), which required that the state prove beyond a reasonable doubt that Eldridge operated a vehicle within Ohio while under the influence of alcohol.

2006State v. Benge, 75 Ohio St.3d 136 , 143 , 1996-Ohio-227 . {¶ 42} In reviewing a claim that a conviction is against the manifest weight of the evidence, an appellate court applies a different test.

13
State v. Bengegreen
ohio · 1996 · cited in 3 Ohio opinions naming this issue, 2006–2015
2 sentences

2015State v. Benge, 75 Ohio St.3d 136, 143 , 1996-Ohio-227 . {¶ 7} Eldridge was convicted of OVI in violation of R.C. 4511.19(A)(1)(a), which required that the state prove beyond a reasonable doubt that Eldridge operated a vehicle within Ohio while under the influence of alcohol.

2006State v. Benge, 75 Ohio St.3d 136 , 143 , 1996-Ohio-227 . {¶ 42} In reviewing a claim that a conviction is against the manifest weight of the evidence, an appellate court applies a different test.

13
State v. Heinishgreen
ohio · 1990 · cited in 1 Ohio opinions naming this issue, 2026–2026
2 sentences

2026Consequently, “‘circumstantial evidence is sufficient to sustain a conviction if that evidence would convince the average mind of the defendant’s guilt beyond a Pickaway App. No. 25CA16 19 reasonable doubt.’” State v. McKnight, 2005-Ohio-6046 , ¶ 75, quoting State v. Heinish, 50 Ohio St.3d 231, 238 (1990). {¶36} Accordingly, when reviewing an insufficient-evidence claim, an appellate court must construe the evidence and all reasonable inferences in a light most favorable to the prosecution.

2026Consequently, “‘circumstantial evidence is sufficient to sustain a conviction if that evidence would convince the average mind of the defendant’s guilt beyond a Pickaway App. No. 25CA16 19 reasonable doubt.’” State v. McKnight, 2005-Ohio-6046, ¶ 75, quoting State v. Heinish, 50 Ohio St.3d 231, 238 (1990). {¶36} Accordingly, when reviewing an insufficient-evidence claim, an appellate court must construe the evidence and all reasonable inferences in a light most favorable to the prosecution.

11
State v. Grantgreen
ohio · 1993 · cited in 1 Ohio opinions naming this issue, 2026–2026
2 sentences

2026E.g., State v. Hill, 75 Ohio St.3d 195 , 205 (1996); State v. Grant, 67 Ohio St.3d 465, 477 (1993).

2026E.g., State v. Hill, 75 Ohio St.3d 195, 205 (1996); State v. Grant, 67 Ohio St.3d 465, 477 (1993).

11
State v. Hillgreen
ohio · 1996 · cited in 1 Ohio opinions naming this issue, 2026–2026
2 sentences

2026E.g., State v. Hill, 75 Ohio St.3d 195 , 205 (1996); State v. Grant, 67 Ohio St.3d 465, 477 (1993).

2026E.g., State v. Hill, 75 Ohio St.3d 195, 205 (1996); State v. Grant, 67 Ohio St.3d 465, 477 (1993).

11
Eastley v. Volkmangreen
ohio · 2012 · cited in 1 Ohio opinions naming this issue, 2020–2020
2 sentences

2020Montgomery No. 22581, 2009-Ohio-525, at ¶ 12 ; see Eastley v. Volkman, 132 Ohio St.3d 328 , 2012-Ohio-2179 , 972 N.E.2d 517 , ¶ 19.

2020Montgomery No. 22581, 2009-Ohio-525, at ¶ 12 ; see Eastley v. Volkman, 132 Ohio St.3d 328 , 2012-Ohio-2179 , 972 N.E.2d 517 , ¶ 19.

11
State v. Thompkinsred
ohio · 1997 · cited in 1 Ohio opinions naming this issue, 2014–2014
1 sentence

2014State v. Thompkins, 78 Ohio St.3d 380, 387 (1997), quoting State v. Martin, 20 Ohio App.3d 172, 175 (1st Dist.1983). {¶ 29} Similar to an insufficient evidence challenge, when addressing a manifest weight challenge the trier of fact is given great deference in our review.

11
State v. Martingreen
ohioctapp · 1983 · cited in 1 Ohio opinions naming this issue, 2014–2014
1 sentence

2014State v. Thompkins, 78 Ohio St.3d 380, 387 (1997), quoting State v. Martin, 20 Ohio App.3d 172, 175 (1st Dist.1983). {¶ 29} Similar to an insufficient evidence challenge, when addressing a manifest weight challenge the trier of fact is given great deference in our review.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
State v. Wilson, 22581 (2-6-2009) green
ohioctapp · 2009
1 sentence

2020Montgomery No. 22581, 2009-Ohio-525, at ¶ 12 ; see Eastley v. Volkman, 132 Ohio St.3d 328 , 2012-Ohio-2179 , 972 N.E.2d 517 , ¶ 19.

12020–2020
State v. Wilson green
ohio · 2007
1 sentence

2014State v. Wilson, 113 Ohio St.3d 382 , 2007-Ohio-2202 , ¶ 26.

12014–2014
State v. Jenks red
ohio · 1991
1 sentence

2006"In reviewing a claim of insufficient evidence, `[t]he relevant inquiry is whether, after viewing the evidence in a light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a reasonable doubt.'" State v. McKnight, 107 Ohio St.3d 101 , 112 , 2005-Ohio-6046 , quoting State v. Jenks (1991), 61 Ohio St.3d 259 , paragraph two of the syllabus. {¶ 12} Furthermore, when deciding an insufficient evidence claim, a reviewing court must not substitute its evaluation of the witnesses' credibility for that of the trier of facts.

12006–2006
State v. McKnight green
ohio · 2005
1 sentence

2006"In reviewing a claim of insufficient evidence, `[t]he relevant inquiry is whether, after viewing the evidence in a light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a reasonable doubt.'" State v. McKnight, 107 Ohio St.3d 101 , 112 , 2005-Ohio-6046 , quoting State v. Jenks (1991), 61 Ohio St.3d 259 , paragraph two of the syllabus. {¶ 12} Furthermore, when deciding an insufficient evidence claim, a reviewing court must not substitute its evaluation of the witnesses' credibility for that of the trier of facts.

12006–2006
In Re Anderson green
ohioctapp · 1996
1 sentence

2006See State v. Benge, 75 Ohio St.3d 136 , 143 , 1996-Ohio-227 . {¶ 13} Appellant was found delinquent for violating R.C. 2907.05 (A)(4), which states, in pertinent part: {¶ 14} "(A) No person shall have sexual contact with another * * * when any of the following applies: {¶ 15} "* * * {¶ 16} "(4) The other person, or one of the other persons, is less than thirteen years of age, whether or not the offender knows the age of that person." {¶ 17} "`Sexual contact' means any touching of an erogenous zone of another, including without limitation the thigh, genitals, buttock, pubic region, or, if the p

12006–2006
State v. Smith green
ohio · 1997
1 sentence

2005State v. Smith (1997), 80 Ohio St.3d 89 , certiorari denied (1998), 523 U.S. 1125 .

12005–2005
Frescas v. Loral Vought Systems Corp. green
scotus · 1998
1 sentence

2005State v. Smith (1997), 80 Ohio St.3d 89 , certiorari denied (1998), 523 U.S. 1125 .

12005–2005
State v. Freeman green
ohioctapp · 2000
1 sentence

2002Willard, at 19; citing State v. Freeman (2000), 138 Ohio App.3d 408 , 424 .

12002–2002
Rohde v. Farmer green
ohio · 1970
1 sentence

1999Rohde v. Farmer (1970), 23 Ohio St.2d 82 , paragraph three of the syllabus.

11999–1999

Where else courts name it

TX 30 (1986–2024) CA 17 (2013–2026) LA 14 (1988–2017) WA 14 (2013–2025) MN 13 (2000–2017) OH 12 (1999–2026) IL 8 (2014–2025) IN 6 (2014–2018) MA 3 (1977–2000) MI 3 (2016–2017) WV 3 (2016–2025) UT 3 (1998–2009) DC 3 (1993–2012) PA 2 (1992–2009) DE 2 (2016–2025) MO 2 (1995–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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