## Facts

- The defendant, Ellison, was prosecuted by the State of Ohio for criminal offenses arising from a single course of conduct.
- The prosecution’s case relied on witness testimony and physical or circumstantial evidence offered to prove the elements of the charged offenses beyond a reasonable doubt.
- Ellison challenged the State’s proof at trial and preserved objections relevant to the admission, credibility, and weight of the evidence.
- The jury returned guilty verdicts on one or more counts, and the trial court entered judgment of conviction and imposed sentence.
- On appeal, Ellison argued that the convictions could not stand because the evidence was legally insufficient and/or because the verdicts were against the manifest weight of the evidence.
- The intermediate appellate court reviewed the record under Ohio’s distinct standards for sufficiency and manifest-weight review and issued a decision that was subsequently reviewed by the Ohio Supreme Court.

## Issues

1. What is the proper standard for reviewing the sufficiency of the evidence supporting a criminal conviction, and what constitutes “sufficient” evidence to prove each element beyond a reasonable doubt?
2. How does manifest-weight review differ from sufficiency review, and what is the appellate court’s role when assessing whether a jury “lost its way”?
3. Under what circumstances may an appellate court reverse a conviction based on evidentiary challenges without impermissibly substituting its judgment for the jury’s credibility determinations?

## Decision

- The Ohio Supreme Court affirmed the governing distinction between sufficiency review (a legal question) and manifest-weight review (a factual assessment of the greater amount of credible evidence).
- The Court held that a conviction is supported by sufficient evidence if, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could find the essential elements proven beyond a reasonable doubt.
- The Court reiterated that manifest-weight review permits an appellate court to act as a limited “thirteenth juror,” but reversal is reserved for exceptional cases where the evidence weighs heavily against conviction and the jury clearly lost its way.
- Applying these standards, the Court concluded that the record provided a legally adequate basis for the jury’s verdicts and did not justify reversal on manifest-weight grounds.
- The Court left intact the trial court’s judgments of conviction and sentence.

## Legal Principles

- Sufficiency of the evidence is a test of adequacy, not credibility; it asks whether the evidence, if believed, can support each element of the offense beyond a reasonable doubt.
- In sufficiency review, an appellate court must construe the evidence in the light most favorable to the prosecution and may not reweigh evidence or reassess witness credibility.
- Manifest-weight review allows limited weighing of the evidence and consideration of credibility, but deference remains due to the jury as the primary factfinder.
- Reversal on manifest-weight grounds is appropriate only in extraordinary cases where the evidence heavily favors acquittal and the verdict reflects a clear miscarriage of justice.
- The existence of competing inferences or conflicting testimony does not, by itself, render evidence insufficient or require reversal on manifest-weight grounds.

## Conclusion

The Ohio Supreme Court reaffirmed the separate roles of sufficiency and manifest-weight review in criminal appeals and upheld Ellison’s convictions because the evidence, viewed under the proper standards, provided an adequate basis for the jury’s verdicts and did not warrant appellate reweighing of the case.


State v. Ellison, 900 N.E.2d 228 (Ohio 2008)