Westlake v. Y.O.

Citations

• 2019 Ohio 2432

Syllabus

Sufficiency of the evidence manifest weight of the evidence domestic violence parental discipline corporal punishment reasonable and proper totality of the circumstances jury instruction jury interrogatory hearsay. Defendant's conviction for domestic violence upheld where the evidence demonstrated that the defendant slapped his ten-year-old son in the face five times, causing injury to the child's eye. The use of parental discipline was neither reasonable nor proper under the totality of the circumstances. The trial court's use of a jury interrogatory was not plain error because it ensured the jury was not criminalizing defendant's conduct that would be reasonable and proper. Trial court did not abuse its discretion in allowing the officer to read the defendant's statement at trial and subsequently admitting the statement into evidence.