State v. Joubert

Citations

• 2024 Ohio 5052

Syllabus

Misdemeanor conviction for domestic violence; sufficiency of the evidence; R.C. 2919.25; if the victim is a person living as spouse, cohabitation must be proven; if the assailant and the victim were not living together, factors in State v. Williams, 79 Ohio St.3d 459 (1997) must be proven; if the parties are living together, the Williams factors need not be proven; State v. McGlothan, 2014-Ohio-85 (2014); the state proved that the victim lived at appellant's house, kept her clothes and personal belongings there, parked her car in his garage, had complete access to his home, and that they slept together; cohabitation was proven; judgment affirmed.