State v. Branch

Summary

The Ohio Fifth District Court of Appeals affirmed Eric Branch's conviction and 36-month sentence for domestic violence. The court held that sufficient evidence established that Branch and the victim were family or household members because they had maintained a romantic relationship and cohabited intermittently.

Holdings

1. The evidence was sufficient for a rational trier of fact to find beyond a reasonable doubt that Branch and P.H. were family or household members because they were cohabiting persons living as spouses.
2. Sufficiency of the evidence presents a question of law reviewed de novo, and a conviction is upheld when, viewing the evidence most favorably to the State, any rational trier of fact could find the essential elements proven beyond a reasonable doubt.

Questions Presented

1. Whether the State presented sufficient evidence that Branch and P.H. were family or household members under Ohio's domestic-violence statute.
2. Whether the evidence established that Branch and P.H. were cohabiting or had cohabited as persons living as spouses.

Disposition

affirmed