State v. Webb

Citations

• 2025 Ohio 456

Syllabus

Patient abuse; plain error; Crim.R. 52(B); sufficiency; knowingly; physical harm. Defendant was convicted after a jury trial of patient abuse. Defendant asserted on appeal that the evidence was insufficient to support two elements of patient abuse: Mens rea of knowingly and whether the victim suffered physical harm as a result. Defendant's conviction is based on sufficient evidence where the State introduced evidence of video surveillance of the incident, training defendant had received, and testimony concerning improper restraint techniques utilized by the defendant. Further, since defendant's defense at trial was that the evidence was insufficient to support the elements for patient abuse, he was precluded from raising a self-defense claim. As such, no plain error occurred when the jury was not instructed as to self-defense.