Summary
The Ohio First District Court of Appeals affirmed William Graves’s burglary conviction under R.C. 2911.12(A)(1). The court held that sufficient evidence supported the conviction and that the trial court’s judgment was not against the manifest weight of the evidence.
Topics
Practice areas
Questions Presented
- Whether the State presented legally sufficient evidence to support Graves's burglary conviction under R.C. 2911.12(A)(1).
- Whether the burglary conviction was against the manifest weight of the evidence because of alleged inconsistencies and credibility concerns in Bolden's testimony.
Holdings
- The evidence was legally sufficient to support Graves's burglary conviction because it permitted a rational trier of fact to find trespass by force in an occupied structure while another person was present and with the purpose to commit a criminal offense.
- The conviction was not against the manifest weight of the evidence because the trial court reasonably credited Bolden's testimony and the corroborating evidence, and it did not clearly lose its way or create a manifest miscarriage of justice.
Key quotations
“whether, after viewing the evidence in a light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime proven beyond a reasonable doubt.” (¶ 11)
“The court must look to and weigh the “evidence and all reasonable inferences, consider[ing] the credibility of witnesses and determine[] whether . . . the [fact finder] clearly lost its way and created such a manifest miscarriage of justice” so as to justify reversal.” (¶ 18)
“Reversing a conviction on manifest-weight grounds is an extraordinary action reserved only for the most “exceptional case in which the evidence weighs heavily against the conviction.”” (¶ 22)
Factual background
Graves entered the secure apartment complex and went to Doneshia Bolden's apartment without her invitation. After Bolden refused to let him in, Graves kicked the locked door, damaged it, forced entry, and engaged in a physical struggle with Bolden. Evidence at trial included Bolden's testimony, photographs of the door and her hand injury, the 911 call, and an officer's body-worn-camera footage; Bolden also testified that Graves took several belongings.
Procedural history
A Hamilton County grand jury indicted Graves for burglary under R.C. 2911.12(A)(1). After a bench trial on January 24, 2025, the Hamilton County Court of Common Pleas found him guilty and sentenced him to an indefinite prison term of two to three years. The First District Court of Appeals overruled both assignments of error and affirmed.