State v. Tripplett

2023 Ohio 4644, 232 N.E.3d 304
CourtOhio Court of Appeals
DecidedDecember 21, 2023
Docket112306
StatusPublished
Cited by4 cases

This text of 2023 Ohio 4644 (State v. Tripplett) 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. Tripplett, 2023 Ohio 4644, 232 N.E.3d 304 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. Tripplett, 2023-Ohio-4644.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff-Appellee, : No. 112306 v. :

KONSHAWNTE TRIPPLETT, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED IN PART, REVERSED IN PART, AND REMANDED RELEASED AND JOURNALIZED: December 21, 2023

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-22-670338-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Benjamin Fuchs, Assistant Prosecuting Attorneys, for appellee.

Law Offices of Jaye M. Schlachet, Jaye M. Schlachet, and Eric M. Levy, for appellant. MICHAEL JOHN RYAN, J.:

Defendant-appellant, Konshawnte Tripplett, appeals his convictions for

two counts of felonious assault and one count of domestic violence against his sister

(referred to herein as “sister” or “victim”), which were rendered after a bench trial.

For the reasons that follow, we affirm in part, reverse in part and remand.

I. Procedural History and Facts

Tripplett met with his sister and another family member at a local bar

to discuss a family dispute. Tripplett’s sister attempted to intervene in a physical

confrontation that occurred between Tripplett and the other family member.

Tripplett assaulted his sister by punching her in the face, hitting her with a bottle on

the mouth, and choking her. She was able to free herself from Tripplett’s grasp.

After the attack, the victim left the scene and drove to another area before calling for

emergency assistance, telling emergency responders that the assault occurred there

and not at the bar. The victim also told police that Tripplett stole her keys and

money but testified that she retrieved her keys from the bar the next day. The victim

needed stitches on the inside and outside of her mouth to close the wound caused

by the bottle. The victim was left with a scar, which she used makeup to conceal.

At the close of the state’s case, Tripplett sought an acquittal under

Crim.R. 29 based on his claim that the victim’s testimony was incredible as it related

to the elements of each crime. The trial court overruled the motion. The trial court

found Tripplett guilty of felonious assault under R.C. 2903.11(A)(1) (causing serious

physical harm), felonious assault under R.C. 2903.11(A)(2) (causing physical harm by means of a deadly weapon), and domestic violence under R.C. 2919.25(A)

(causing physical harm to a family member). The trial court requested a

presentence-investigation report and set a date for a sentencing hearing. At his

sentencing hearing, Tripplett did not raise the issue of whether any of his offenses

merged as allied offenses of similar import. The trial court imposed an 18-month

term of community-control sanctions for each offense, with conditions.

Tripplett filed a delayed notice of appeal and raises four assignments of

error for our review:

I. The trial court committed plain error when it failed to merge appellant’s convictions.

II. Appellant’s rights under the Sixth Amendment to the United States Constitution made applicable to the state of Ohio through the Fourteenth Amendment were violated when he received ineffective assistance of trial counsel.

III. The three convictions entered against appellant must be vacated with appellant acquitted of all charges as the convictions are not supported by sufficient evidence.

IV. The three convictions entered against appellant must be vacated and the case remanded for a new trial as the convictions are against the manifest weight of the evidence presented at trial.

II. Law and Analysis

A. Sufficiency and manifest weight of the evidence

For ease of review, we will first discuss Tripplett’s third and fourth

assignments of error in which Tripplett claims his convictions were not supported by sufficient evidence and were against the manifest weight of the evidence.1

The test for sufficiency of the evidence requires a determination of

whether the prosecution met its burden of production at trial. State v. Bowden,

8th Dist. Cuyahoga No. 92266, 2009-Ohio-3598, ¶ 12. An appellate court’s function

when reviewing the sufficiency of the evidence to support a criminal conviction is to

examine the evidence admitted at trial to determine whether such evidence, if

believed, would convince the average mind of the defendant’s guilt beyond a

reasonable doubt. State v. Murphy, 91 Ohio St.3d 516, 543, 747 N.E.2d 765 (2001).

“‘The relevant inquiry is 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.’” State v. Walker, 150 Ohio St.3d

409, 2016-Ohio-8295, 82 N.E.3d 1124, ¶ 12, quoting State v. Jenks, 61 Ohio St.3d

259, 574 N.E.2d 492 (1991), paragraph two of the syllabus.

Serious physical harm

Tripplett claims that the state (1) failed to prove serious physical harm

for the purpose of the R.C. 2903.11(A)(1) felonious assault conviction; (2) failed to

prove that the bottle constituted a “deadly weapon” for the purpose of the

R.C. 2903.11(A)(2) felonious assault conviction; and (3) failed to demonstrate that

the victim and Tripplett were biologically related for the purposes of the

R.C. 2919.25(A) domestic violence conviction.

1 If we were to find that there was insufficient evidence to support his convictions

or that they were against the manifest weight of the evidence, it would not be necessary to consider the remaining assignments of error. See App.R. 12. “Serious physical harm” is defined, in pertinent part, as “[a]ny physical

harm that carries a substantial risk of death”; “[a]ny physical harm that involves

some permanent incapacity, whether partial or total, or that involves some

temporary, substantial incapacity”; or “[a]ny physical harm that involves some

permanent disfigurement or that involves some temporary, serious disfigurement.”

R.C. 2901.01(A)(5).

Tripplett contends that there was insufficient evidence to support the

element of “serious physical harm” because the state failed to show that the victim

lost consciousness. This court has held that the temporary loss of consciousness,

“irrespective of duration,” constitutes a temporary substantial incapacity and,

therefore, is considered a serious physical harm under R.C. 2901.01(A)(5). State v.

Chambers, 8th Dist. Cuyahoga No. 99864, 2014-Ohio-390, ¶ 23. The victim

testified that she was “fading away” before “all of a sudden” regaining the ability to

fight free. Thus, according to Tripplett, she never lost consciousness and any harm

suffered does not rise to the level of serious physical harm.

The victim testified that Tripplett assaulted her by punching her in the

head, hitting her in the face with a bottle, and choking her. Because Tripplett was

convicted of one count of felonious assault (serious physical harm), the state had to

show that only one of his acts caused serious physical harm, not that each or more

than one of his actions against his sister caused this harm.

‘“This court has consistently held that the need for stitches constitutes

serious physical harm for purposes of a felonious assault conviction.” State v. Wynn, 8th Dist. Cuyahoga No. 103824, 2017-Ohio-4062, ¶ 8, quoting State v.

Studgions, 8th Dist.

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2023 Ohio 4644, 232 N.E.3d 304, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-tripplett-ohioctapp-2023.