State v. Hoffmeyer

Summary

The Ninth District Court of Appeals of Ohio affirmed Samuel Hoffmeyer’s conviction for felony domestic violence. The court held that sufficient evidence supported the finding that Hoffmeyer and the victim cohabited as spouses, rejected the manifest-weight challenge, and concluded that trial counsel was not constitutionally ineffective. Judge Carr dissented from the ineffective-assistance determination.

Holdings

1. The evidence was legally sufficient to establish that L.R. and Hoffmeyer cohabited as spouses and therefore that L.R. was a family or household member under R.C. 2919.25(F).
2. The domestic-violence conviction was not against the manifest weight of the evidence.
3. Hoffmeyer failed to establish ineffective assistance because counsel's challenged decisions did not fall below an objective standard of reasonable representation.

Questions Presented

1. Whether sufficient evidence supported the domestic-violence conviction, including proof that L.R. was a family or household member because she and Hoffmeyer cohabited.
2. Whether the domestic-violence conviction was against the manifest weight of the evidence.
3. Whether trial counsel rendered ineffective assistance by failing to present portions of a police body-camera recording and by failing to call Hoffmeyer's parole officer regarding his registered address.

Disposition

affirmed