State v. Curtis

Citations

• 157 N.E.3d 879
• 2020 Ohio 4152

Syllabus

Appellant's conviction for nonsupport under R.C. 2919.21(B) was not against the manifest weight of the evidence. The evidence indicated that appellant did not support her children as required by court order, and appellant also failed to prove her affirmative defense under R.C. 2919.21(D). In addition, trial counsel did not render ineffective assistance of counsel by failing to make a Crim.R. 29 motion for acquittal, which is based on insufficiency of the evidence. Such a motion would not have changed the outcome of the trial because the conviction was not against the manifest weight of the evidence, which subsumes the issue of sufficiency. Judgment affirmed.