State v. Snow

Citations

• 2026 Ohio 1364

Syllabus

DOMESTIC VIOLENCE — REASONABLE PARENTAL DISCIPLINE — R.C. 1.51 — JAIL TIME CREDIT: Defendant's conviction for domestic violence was not contrary to the manifest weight of the evidence where there was video evidence showing the defendant punching her daughter and the court determined that that act was not reasonable parental discipline. The State could choose to prosecute the defendant for domestic violence and assault rather than endangering children pursuant to R.C. 1.51 because the child endangering statute contains different elements. The trial court erred by failing to award jail time credit where defendant spent one day in jail and the cause must be remanded for the trial court to award defendant proper jail time credit.