State v. Fogle

2026 Ohio 722
CourtOhio Court of Appeals
DecidedMarch 3, 2026
Docket25CA00042
StatusPublished

This text of 2026 Ohio 722 (State v. Fogle) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Fogle, 2026 Ohio 722 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Fogle, 2026-Ohio-722.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO, Case No. 25CA00042

Plaintiff - Appellee Opinion & Judgment Entry

-vs- Appeal from the Court of Common Pleas of Licking County, TRACY LEE FOGLE, Case No. 2024CR000619

Defendant - Appellant Judgment: Affirmed

Date of Judgment: March 3, 2026

BEFORE: William B. Hoffman; Andrew J. King; David M. Gormley, Judges

APPEARANCES: Jenny R. Wells (Licking County Prosecuting Attorney) & Kenneth W. Oswalt (Assistant Prosecuting Attorney), Newark, Ohio, for Plaintiff-Appellee; Brian A. Smith, Fairlawn, Ohio, for Defendant-Appellant.

Gormley, J.

{¶1} Appellant Tracy Fogle challenges her convictions on charges of felonious

assault, improperly handling a firearm in a motor vehicle, and aggravated menacing.

According to Fogle, the State’s evidence at trial was insufficient to support her conviction

for felonious assault, and she argues, too, that her convictions on all three charges were

against the manifest weight of the evidence. Fogle also contends that the trial court

improperly limited her counsel’s cross-examination of a witness and argues that her trial

counsel was ineffective because that attorney did not file a motion to suppress. After

considering each of Fogle’s arguments in turn, we see no reason to overturn her

convictions. The trial court’s judgment is affirmed. The Key Facts

{¶2} On the evening of August 23, 2024, R.S. and K.G. arrived at the Mary Ann

Township fire station in Licking County and reported that Fogle had shot at them and that

Fogle had been struck by their vehicle. Minutes later, Fogle herself called 9-1-1 from the

parking lot of a business located across the street from the fire station and reported that

she had been struck by a vehicle and was injured.

{¶3} Earlier in the evening, R.S. and K.G. — who were dating at the time of the

incident — were at K.G.’s home when Fogle (who is K.G.’s sister) arrived. According to

testimony from Fogle’s trial, K.G. then stepped out of her home and spoke with Fogle

while Fogle remained in her vehicle. During that conversation, K.G. noticed a handgun

under Fogle’s leg. K.G. asked Fogle why she had a handgun, and Fogle responded that

she thought perhaps she was coming there to shoot K.G. K.G. testified that Fogle had

an open can of beer in her vehicle and smelled of alcohol. Fogle refused to leave when

K.G. asked her to, so R.S. and K.G. left and drove around for a while.

{¶4} When R.S. and K.G. returned to the residence, they discovered that Fogle

— who was still sitting in her vehicle — had been drinking beer and throwing the empty

cans onto the road. K.G. and Fogle both stepped out of their vehicles to speak to each

other, and K.G. noticed that Fogle had a handgun tucked into her waistband. Fogle and

K.G. scuffled briefly, and, as K.G. walked away, Fogle pointed the handgun at K.G. and

pulled the trigger several times. K.G. testified that she heard a clicking noise as Fogle

pulled the trigger.

{¶5} R.S. revved the engine of his vehicle, and Fogle then pointed the handgun

at him and again pulled the trigger. Next, R.S. struck Fogle with the front of his vehicle. Fogle — who was still on foot outside her vehicle — then walked toward K.G. again, and

K.G. took the gun from her and tossed it aside. K.G. then climbed into R.S.’s vehicle, and

R.S. drove them to the fire station.

{¶6} When law-enforcement officers approached Fogle at the business across

the street from the fire station, she had injuries to her head and legs, smelled of alcohol,

and appeared highly intoxicated. Fogle admitted to drinking alcohol, and a search of her

vehicle revealed a can of beer, a loaded magazine for a handgun, additional ammunition,

and a holster. When they went to the scene where the encounter outside K.G.’s home

had occurred, law-enforcement officers saw Fogle’s shoe and glasses, a broken-off piece

of R.S.’s vehicle, an empty beer can, a handgun with an empty magazine, and skid and

yaw marks in the roadway. The following day, the sheriff’s office received a call from a

neighbor who lived on the same street as K.S., and that neighbor reported having found

a handgun in her mailbox. A deputy retrieved the handgun, which belonged to Fogle.

{¶7} Fogle was indicted on multiple criminal charges. After a jury trial, Fogle was

found guilty of felonious assault (a second-degree felony) with a firearm specification,

improperly handling a firearm in a motor vehicle (a fifth-degree felony), and aggravated

menacing (a first-degree misdemeanor). Fogle now appeals her convictions.

Fogle’s Conviction for Felonious Assault is Supported by Sufficient Evidence

{¶8} In her first assignment of error, Fogle argues that the State failed to present

sufficient evidence to support her conviction on the felonious-assault charge.

{¶9} “When reviewing the sufficiency of the evidence, an appellate court does

not ask whether the evidence should be believed but, rather, whether the evidence, ‘if

believed, would convince the average mind of the defendant’s guilt beyond a reasonable doubt.’” State v. Pountney, 2018-Ohio-22, ¶ 19, quoting State v. Jenks, 61 Ohio St.3d

259 (1991), paragraph two of the syllabus. “‘The relevant inquiry is whether, after viewing

the evidence in the 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.’”

State v. Howell, 2020-Ohio-174, ¶ 28 (5th Dist.), quoting Jenks at paragraph two of the

syllabus. A “verdict will not be disturbed unless the appellate court finds that reasonable

minds could not reach the conclusion reached by the trier-of-fact.” State v. Dennis, 79

Ohio St.3d 421, 430 (1997).

{¶10} To prove the R.C. 2903.11(A)(2) charge of felonious assault, the State was

required to introduce evidence that Fogle knowingly “[c]ause[d] or attempt[ed] to cause

physical harm to another . . . by means of a deadly weapon.” A firearm is considered a

deadly weapon, whether it is loaded or unloaded. State v. Meek, 53 Ohio St.2d 35, 39

(1978). See also R.C. 2923.11(B)(1) (“‘Firearm’ includes an unloaded firearm”).

{¶11} Fogle argues that the State’s evidence was insufficient to show that she

knowingly caused or attempted to cause physical harm to either K.G. or R.S. “A person

acts knowingly, regardless of purpose, when the person is aware that the person’s

conduct will probably cause a certain result or will probably be of a certain nature.” R.C.

2901.22(B).

{¶12} “[T]he word ‘knowingly’ in the statute . . . applies to the activity of . . .

point[ing] the weapon and fir[ing] the shots.” State v. Phillips, 77 Ohio App.3d 663, 665

(2d Dist. 1991). Felonious assault entails at least an “attempt to cause harm by means

of a deadly weapon” even when “no harm results.” Id. at 666. {¶13} To be sure, “[t]he act of pointing a deadly weapon at another, without

additional evidence regarding the actor’s intention, is insufficient evidence to convict a

defendant of the offense of ‘felonious assault’ as defined by R.C. 2903.11(A)(2).” State

v. Brooks, 44 Ohio St.3d 185, 192 (1989). When that “act of pointing a deadly weapon at

another” is, however, “coupled with a threat, which indicates an intention to use such

weapon, [there] is sufficient evidence to convict a defendant of the offense of ‘felonious

assault.’” State v.

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Bluebook (online)
2026 Ohio 722, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-fogle-ohioctapp-2026.